Opinion
5999-22
06-17-2022
OSCAR PATINO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 9, 2022, this Court, which is separate and independent from the IRS, received from petitioner an imperfect petition. Petitioner appears to seek to challenge a notice of deficiency, dated December 6, 2021, issued with respect to his 2019 tax year. On April 11, 2022, respondent filed a Motion to Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted.
Upon due consideration, it is ORDERED that, on or before July 11, 2022, petitioner shall file an Objection, if any, to respondent's above-referenced motion, as supplemented (respondent's motion). Failure to file an objection may result in the granting of respondent's motion and dismissal of this case. It is further
ORDERED that, on or before July 11, 2022, petitioner may file an amended petition (see attached form). Petitioner is advised that the amended petition should contain clear and concise assignments of each and every error that petitioners allege the Commissioner to have committed in the notice of deficiency issued to petitioners for the 2018 tax year. Further, the amended petition should contain clear and concise lettered statements of the facts on which petitioners base the assignments of error. See Rule 34(b), Tax Court Rules of Practice and Procedure; Jarvis v. Commissioner, 78 T.C. 646, 658 (1982). The Tax Court Rules of Practice and Procedure are available on the Court's website www.ustaxcourt.gov.