Opinion
8240-21S
12-23-2021
John Stirling Applegarth Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On March 11, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on July 13, 2021, 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. Accordingly, upon due consideration, it is
ORDERED that, on or before January 11, 2022, respondent shall file a report and shall attach thereto a complete copy of the notice of deficiency for 2017 issued to petitioner.