Opinion
9774-21
02-01-2023
ALI FAWZI AL-MAHMOD & SANA SALIM ELIAS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On March 15, 2021, the Court received from petitioners correspondence, attached to which was a copy of a notice of deficiency issued to petitioners with respect to the 2018 taxable year. To protect petitioners' statutory time period within which to begin a case, the Court filed that document as a petition to commence this case at Docket No. 9774-21. The Court on June 9, 2021, then issued an Order which directed petitioner to file an Amended Petition and to pay the filing fee for the case.
On May 9, 2022, petitioners paid the filing fee. At this juncture, upon further review of the record herein, the Court is satisfied that the original petition is sufficient to comply with the general standards of notice pleading as set forth in Rule 31 of the Tax Court Rules of Practice and Procedure.
Accordingly, the premises considered, it is
ORDERED that petitioners no longer need comply with the Court's Order served June 9, 2021, insofar as it directed the filing of an Amended Petition. It is further
ORDERED that respondent shall file an answer to the petition on or before March 31, 2022.