Opinion
19363-22
10-14-2022
CHRISTIE SIEVERS & KEVIN SIEVERS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion To Dismiss for Failure To State a Claim Upon Which Relief Can Be Granted, filed October 13, 2022, in the above-docketed case, it is
ORDERED that petitioners shall, on or before November 18, 2022, file an objection, if any, to respondent's just-referenced motion. It is further
ORDERED that, on or before November 18, 2022, petitioners may file with the Court a proper amended petition that sets forth clear and concise assignments of each and every error that petitioner alleges to have been committed by the Commissioner in the determination of the deficiencies, additions to tax, and/or penalties in dispute in this case, and clear and concise lettered statements of the facts on which petitioner bases the assignments of error. See Rule 34(b), Tax Court Rules of Practice and Procedure; Jarvis v. Commissioner, 78 T.C. 646, 658 (1982).