Opinion
17580-22S
10-04-2022
DWAYNE M. WRIGHT & MELISSA J. SAPP, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 10, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on September 30, 2022, 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. In particular, the materials presently in the record suggest jurisdictional concerns. Accordingly, upon due consideration, it is
ORDERED that, on or before October 28, 2022, respondent shall file either: (1) An appropriate jurisdictional motion; and/or (2) a report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation.