Opinion
5577-22
07-27-2022
JEFFREY K. COINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 14, 2022, respondent filed 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 Motion for More Definite Statement Pursuant to Rule 51 is granted. It is further
ORDERED that, on or before August 17, 2022, petitioner shall file with the Court a proper amended petition (see attached form), 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 complete copy of each notice on which petitioner relies to establish the jurisdiction of the Court over this proceeding.