Opinion
17873-21
07-25-2022
MARIO Z. MEDINILLA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 21, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on September 29, 2021, by respondent's answer thereto. However, upon further review, it came to the Court's attention that although the pleadings may reference the notice or notices of deficiency or determination upon which this litigation is based, no complete copy of such notice(s) had been provided. It was therefore advisable to ensure that the record herein was complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods, and respondent was directed to file relevant materials.
Subsequently, on July 11, 2022, respondent filed a response indicating that additional time was needed to obtain the documentation. Accordingly, upon due consideration, it is
ORDERED that, on or before August 22, 2022, respondent shall file either: (1) An appropriate jurisdictional motion; and/or (2) a further report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation. 1