Opinion
31019-21L
03-16-2022
Dakota Bus Service, Inc Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On February 11, 2022, petitioner's counsel filed a Letter Dated February 4, 2022. Among other things, attached to that letter is an amended petition with an attached notice of determination concerning collection action issued to petitioner for tax periods ending 6/2014, 6/2015, 6/2018, 9/2018, 12/2018, 3/2019, and 6/2019. As respondent has answered the petition on December 29, 2021, and petitioner no longer may file an amended petition as of right, any amended petition must be lodged concurrently with an appropriate motion for leave to file amended petition. See Rule 41(a), Tax Court Rules of Practice and Procedure. No motion for leave to file amended petition accompanied petitioner's amended petition and, therefore, petitioner's amended petition has not been filed in the record in this case.
Upon due consideration, it is
ORDERED that, on or before April 18, 2022, petitioner may file an appropriate motion for leave to file amended petition and concurrently lodge therewith an amended petition in accordance with Rule 41(a).