Opinion
31219-21
03-16-2022
Chris G. Mosher and Erin C. Mosher Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On December 28, 2021, respondent filed in this case a Motion for More Definite Statement Pursuant to Rule 51 of the Tax Court Rules of Practice and Procedure. Upon due consideration, for the reasons set forth in respondent's motion, it is
ORDERED that respondent's above-referenced Motion for More Definite Statement Pursuant to Rule 51 is granted. It is further
ORDERED that, on or before April 7, 2022, petitioners shall file with the Court a proper amended petition (see form attached), which shall include (1) the date of the notice(s) of deficiency or notice(s) of determination being disputed and the taxable year(s) for which such notice(s) was/were issued; (2) clear and concise lettered assignments of each and every error petitioners allege was committed by respondent (i.e., the Internal Revenue Service (IRS)) in the notice(s) of deficiency or determination underlying this proceeding; and (3) clear and concise lettered statements of every fact upon which petitioners base each assignment of error. See Rules 34(b)(4) and (5), 331(b)(4) and (5), Tax Court Rules of Practice and Procedure. Failure to comply with this Order may result in the dismissal of this case for lack of jurisdiction. It is further
ORDERED that petitioners shall attach to the amended petition a copy of each notice on which petitioners rely to establish the jurisdiction of the Court over this proceeding.