Opinion
7323-21S
09-17-2021
Michael L. Rosenstock & Chanta W. Rosenstock Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On March 1, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on July 1, 2021, by a First Amended Petition and on August 4, 2021, by respondent's answer thereto. However, upon further review, it has come 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) has been provided. It is therefore advisable to ensure that the record herein is complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods. Accordingly, upon due consideration, it is
ORDERED that, on or before October 15, 2021, respondent shall file a report and shall attach thereto a complete copy of the notice of deficiency for 2017 issued to petitioners. It is further
ORDERED that the Clerk of the Court is directed to serve on petitioners at the address of record a copy of the Answer to Amended Petition filed August 4, 2021.
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