Opinion
4571-24P
05-08-2024
CELIO BURROWES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
Upon due consideration of respondent's Motion to Dismiss for Failure to State a Claim upon Which Relief Can Be Granted, filed May 7, 2024, it is
ORDERED that, on or before May 31, 2024, petitioner shall file an objection, if any, to respondent's above-referenced Motion. Failure to comply with this Order may result in the granting of the Motion to Dismiss. It is further
ORDERED that, on or before May 31, 2024, petitioner may file a proper amended petition that among other things sets forth: (1) lettered statements explaining why petitioner disagrees with the certification or the failure to reverse the certification and (2) lettered statements setting forth the facts upon which petitioner relies to support petitioner's position. See Rule 351(b), Tax Court Rules of Practice and Procedure.