Opinion
15418-21
03-11-2022
Marc Crumpton & Nicole Panucci Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On May 3, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on September 16, 2021, by a First Amended Petition and on November 19, 2021, by respondent's answer thereto (albeit mistitled). However, upon further review, it has come to the Court's attention that although the pleadings may reference the notice or notices of deficiency or determination upon which this litigation is based, no complete copy of such notice(s) has been provided. It is therefore advisable to ensure that the record herein is complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods. Accordingly, upon due consideration, it is
ORDERED that, on or before April 11, 2022, respondent shall file either: (1) An appropriate jurisdictional motion; and/or (2) a report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation. It is further
ORDERED that the document filed November 19, 2021, as an Answer shall be recharacterized as an Answer to Amended Petition.