Opinion
33865-21
03-24-2022
Mario Gerard Bernadel Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration and for cause, it is
ORDERED that respondent's Motion for More Definite Statement Pursuant to Rule 51, filed January 24, 2022, is granted. It is further
ORDERED that, on or before April 11, 2022, petitioner shall file with the Court a proper amended petition which shall include (1) the date of the notice(s) being disputed and the taxable year(s) for which such notice(s) was/were issued; (2) clear and concise lettered assignments of each and every error petitioner alleges was committed by the Internal Revenue Service in the notice(s) underlying this proceeding; and (3) clear and concise lettered statements of every fact upon which petitioner bases each assignment of error. See Rules 34(b)(4) and (5), 331(b)(4) and (5), Tax Court Rules of Practice and Procedure. Failure to comply with this Order may result in the dismissal of this case for lack of jurisdiction. It is further
ORDERED that petitioner shall attach to the amended petition a copy of each notice on which petitioner relies to establish the jurisdiction of the Court over this proceeding. It is further
ORDERED that petitioner's Motion for Extension of Time, filed February 14, 2022, is denied as moot. 1