Opinion
13810-22
07-29-2022
JULIO YADAICELA, Petitioner 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 July 19, 2022, in the above-docketed case, it is
ORDERED that petitioner shall, on or before August 22, 2022, file an objection, if any, to respondent's just-referenced motion. It is further
ORDERED that, on or before August 22, 2022, petitioner may file with the Court a proper amended petition (in English) 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).