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Smith v. Comm'r of Internal Revenue

United States Tax Court
Mar 29, 2022
No. 2189-22 (U.S.T.C. Mar. 29, 2022)

Opinion

2189-22

03-29-2022

Tyler Smith Petitioner v. Commissioner of Internal Revenue, Respondent


ORDER

Maurice B. Foley, Chief Judge

The Court filed on February 16, 2022, a document as the petition of the above-named petitioner at the docket number indicated. That docket number MUST appear on all documents and papers subsequently sent to the Court for filing or otherwise. The document did not comply with the Rules of the Court as to the form and content of a proper petition. Accordingly, it is

ORDERED that on or before May 25, 2022, petitioner shall file a proper amended petition on the form enclosed. If an Amended Petition is not received on or before May 25, 2022, the case will be dismissed or other action taken as the Court deems appropriate. 1

AMENDED PETITION

1. Please check the appropriate box(es) to show which IRS NOTICE(s) you dispute:

[] Notice of Deficiency

[] Determination of Worker Classification*

[] Notice of Determination Concerning Collection Action

[] Notice of Determination Concerning Your Request for Relief From Joint and Several Liability.

[] Notice of Final Determination Not to Abate Interest*

*Please see the Court's Web site, www.ustaxcourt.gov, or information booklet for additional information if (1) you filed a claim for interest abatement or requested relief from joint and several liability, and the IRS has not made a determination, or (2) the petition involves a worker classification case.

2. Provide the date(s) the IRS issued the NOTICE(S) checked above and the city and State of the IRS office(s) issuing the NOTICE(S):___

3. Provide the year(s) or period(s) for which the NOTICE(S) was/were issued:___

4.SELECT ONE OF THE FOLLOWING:

If you want your case conducted under small tax case procedures, check here: [] (CHECK)

If you want your case conducted under regular tax case procedures, check here: [] (ONE BOX)

NOTE: A decision in a "small tax case" cannot be appealed to a Court of Appeals by the taxpayer or the IRS. If you do not check either box, the Court will file your case as a regular tax case.

5. Explain why you disagree with the IRS determination in this case (please list each point separately): 2

6. State the facts upon which you rely (please list each point separately):

You may use additional pages to explain why you disagree with the IRS determination or to state additional facts. Please do not submit tax forms, receipts, or other types of evidence with this petition.

ENCLOSURES:

Please check the appropriate boxes to show that you have enclosed the following items with this petition:

[] A copy of any NOTICE(S) the IRS issued to you

[] Statement of Taxpayer Identification Number (Form 4) (See PRIVACY NOTICE below)

[] The Request for Place of Trial (Form 5)

[] The filing fee

PRIVACY NOTICE: Form 4 (Statement of Taxpayer Identification Number) will not be part of the Court's public files. All other documents filed with the Court, including this Petition and any IRS Notice that you enclose with this Petition, will become part of the Court's public files. To protect your privacy, you are strongly encouraged to omit or remove from this Petition, from any enclosed IRS Notice, and from any other document (other than Form 4) your taxpayer identification number (e.g., your Social Security number) and certain other confidential information as specified in the Tax Court's "Notice Regarding Privacy and Public Access to Case Files", available at www, ustaxcourt. gov. 3


Summaries of

Smith v. Comm'r of Internal Revenue

United States Tax Court
Mar 29, 2022
No. 2189-22 (U.S.T.C. Mar. 29, 2022)
Case details for

Smith v. Comm'r of Internal Revenue

Case Details

Full title:Tyler Smith Petitioner v. Commissioner of Internal Revenue, Respondent

Court:United States Tax Court

Date published: Mar 29, 2022

Citations

No. 2189-22 (U.S.T.C. Mar. 29, 2022)