Opinion
170-22S
03-10-2022
Chad E. Dale & Jacquelyn J. Dale Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On January 4, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on March 4, 2022, by respondent's answer thereto. 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 20, 2022, respondent shall file a report and shall attach thereto a complete copy of the notice of deficiency for 2018 issued to petitioners.