Opinion
26964-21S
06-27-2022
DOUGLAS A. PHILLIPS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
By Order served May 24, 2022, the Court directed respondent to file a response and to attach thereto a complete copy of the notice of deficiency upon which this case is based.
On June 13, 2022, respondent filed a Response and attached thereto a copy of a Notice of Deficiency dated February 22, 2021, determining a deficiency of $947 in petitioner's federal income tax for the 2018 taxable year.
However, upon further review of the Petition, filed July 23, 2021, the Court notes that attached thereto is a partial copy of a Notice of Deficiency dated April 19, 2021, also determining a deficiency of $947 in petitioner's federal income tax for the 2018 taxable year. The Court is unable to reconcile respondent's Response (and the Notice of Deficiency attached thereto) with the Petition (and the partial Notice of Deficiency attached thereto).
Upon due consideration of the foregoing, it is
ORDERED that, on or before July 18, 2022, respondent shall file a supplement to his above-referenced Response. That supplement shall address the discrepancy noted by the Court above and shall attach thereto a complete copy of the Notice of Deficiency dated April 19, 2021, determining a deficiency of $947 in petitioner's federal income tax for the 2018 taxable year.