Opinion
10371-23S
08-21-2023
OLUREMILEKUN M. AKANBI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 15, 2023, respondent filed a Motion for More Definite Statement Pursuant to Rule 51 of the Tax Court Rules of Practice and Procedure. Upon due consideration, and for the reasons set forth in that Motion, it is
ORDERED that respondent's above-referenced Motion is granted. It is further
ORDERED that, on or before September 20, 2023, petitioner shall file with the Court a proper amended petition (see form attached), which shall contain (1) the date(s) of the notice(s) of deficiency or notice(s) of determination in dispute and the taxable year(s) for which such notice(s) was/were issued; (2) clear and concise lettered assignments of each and every error which petitioner alleges to have been committed by respondent (i.e., the Internal Revenue Service) in the notice(s) of deficiency or notice(s) of determination underlying this proceeding; and (3) clear and concise lettered statements of the facts on which petitioner bases each assignment of error. See Rules 34(b) & 331(b), Tax Court Rules of Practice and Procedure. It is further
ORDERED that petitioner shall attach to the amended petition filed pursuant to this Order a copy of each notice on which petitioner relies to establish the jurisdiction of the Court over this proceeding.
Petitioner is informed that failure to comply in full with this Order may result in the dismissal of this case or other appropriate action by the Court.