Opinion
26775-21
02-02-2022
Thomas Eugene Calhoun, Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On November 26, 2021, 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, 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 February 24, 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 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 petitioner alleges 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 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. 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. 1