Opinion
32770-21
04-18-2022
JOSEPH BELCIK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge.
Upon due consideration of respondent's Motion To Dismiss for Failure To State a Claim Upon Which Relief Can Be Granted, filed February 4, 2022, in the above-docketed case, it is
ORDERED that petitioner shall, on or before May 16, 2022, file an objection, if any, to respondent's just-referenced motion. It is further
ORDERED that, on or before May 16, 2022, petitioner may file with the Court a proper amended petition 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).