Opinion
8993-21
01-11-2023
ASHLEY KINCAID RICH & MICHAEL WILLIAM RICH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN, CHIEF JUDGE.
On May 27, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on September 28, 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 appropriate materials.
Subsequently, on May 11, August 16, and December 16, 2022, respondent filed initial reports indicating that efforts remained ongoing and additional time was needed. Accordingly, upon due consideration, it is
ORDERED that, on or before May 11, 2023, respondent shall file a further report and shall attach thereto a complete copy of the notice of deficiency for 2017 issued to petitioners.