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Bryan v. Comm'r of Internal Revenue

United States Tax Court
Aug 24, 2022
No. 15035-22 (U.S.T.C. Aug. 24, 2022)

Opinion

15035-22

08-24-2022

CHRISTOPHER SHAUN BRYAN Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

On August 22, 2022, respondent filed in this case a Motion for More Definite Statement Pursuant to Rule 51 of the Tax Court Rules of Practice and Procedure. Upon due consideration, for the reasons set forth in respondent's motion, it is

ORDERED that respondent's above-referenced Motion for More Definite Statement Pursuant to Rule 51 is granted. It is further

ORDERED that, on or before September 15, 2022, petitioner shall file with the Court a proper amended petition (see form attached), which shall include (1) the date of the notice(s) of deficiency or notice(s) of determination 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 petitioners allege was committed by respondent (i.e., the Internal Revenue Service (IRS)) in the notice(s) of deficiency or determination underlying this proceeding; and (3) clear and concise lettered statements of every fact upon which petitioners base each assignment of error. See Rules 34(b)(4) and (5), 331(b)(4) and (5), Tax Court Rules of Practice and Procedure. 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.

AMENDED PETITION

1. Please check the appropriate box(es) to show which IRS ACTION(S) you dispute:

[ ] Notice of Deficiency

[ ] Notice of Determination Concerning Collection Action

[ ] Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015 (or Failure of IRS to Make Determination Within 6 Months After Election or Request for Relief)*

[ ] Notice of Final Determination for [Full/Partial] Disallowance of Interest Abatement Claim (or Failure of IRS to Make Final Determination Within 180 Days After Claim for Abatement)*

[ ] Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the Department of State

[ ] Notice of Determination Under Section 7623 Concerning Whistleblower Action*

[ ] Notice of Determination of Worker Classification*

*For additional information, please see "Taxpayer Information: Starting a Case" at www.ustaxcourt.gov (accessible by hyperlink from asterisks above, or in the Court's information booklet).

2. If applicable, provide the date(s) the IRS issued the NOTICE(S) checked above and the city and State of the IRS office(s) issuing the NOTICE(S):___

3. Provide the year(s) or period(s) for which the NOTICE(S) was/were issued: ___

4. SELECT ONE OF THE FOLLOWING (unless your case is a whistleblower or a certification action):

If you want your case conducted under small tax case procedures, check here: [ ] CHECK

If you want your case conducted under regular tax case procedures, check here: [ ] ONE BOX

NOTE: A decision in a "small tax case" cannot be appealed to a Court of Appeals by the taxpayer or the IRS. If you do not check either box, the Court will file your case as a regular tax case.

5. Explain why you disagree with the IRS determination in this case (please list each point separately):

6. State the facts upon which you rely (please list each point separately):

You may use additional pages to explain why you disagree with the IRS determination or to state additional facts. Please do not submit tax forms, receipts, or other types of evidence with this petition.

ENCLOSURES:

Please check the appropriate boxes to show that you have enclosed the following items with this petition:

[ ] A copy of any NOTICE(S) the IRS issued to you

[ ] Statement of Taxpayer Identification Number (Form 4) (See PRIVACY NOTICE below)

[ ] The Request for Place of Trial (Form 5) [ ] The filing fee

PRIVACY NOTICE: Form 4 (Statement of Taxpayer Identification Number) will not be part of the Court's public files. All other documents filed with the Court, including this Petition and any IRS Notice that you enclose with this Petition, will become part of the Court's public files. To protect your privacy, you are strongly encouraged to omit or remove from this Petition, from any enclosed IRS Notice, and from any other document (other than Form 4) your taxpayer identification number (e.g., your Social Security number) and certain other confidential information as specified in the Tax Court's "Notice Regarding Privacy and Public Access to Case Files", available at www.ustaxcourt.gov.


Summaries of

Bryan v. Comm'r of Internal Revenue

United States Tax Court
Aug 24, 2022
No. 15035-22 (U.S.T.C. Aug. 24, 2022)
Case details for

Bryan v. Comm'r of Internal Revenue

Case Details

Full title:CHRISTOPHER SHAUN BRYAN Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Aug 24, 2022

Citations

No. 15035-22 (U.S.T.C. Aug. 24, 2022)