Opinion
25763-21
06-22-2022
MADHU S. POTLA & JAYAPRADA POTLA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 19, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on November 22, 2021, by respondent's answer thereto. However, upon further review, it came to the Court's attention that although the pleadings might 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. At that juncture, respondent was directed to file an appropriate motion or report to clarify the record and jurisdictional parameters.
Subsequently, on June 21, 2022, respondent filed a report requesting additional time to secure relevant materials.
Accordingly, upon due consideration, it is
ORDERED that, on or before August 22, 2022, respondent shall file a report and shall attach thereto a complete copy of the notice of deficiency for 2017 and 2018 issued to petitioners.