Opinion
15956-22
12-06-2023
PAUL K. DAVIDSON & MARGARET R. SPENCER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On July 18, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on September 7, 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 copy of any such notice as to all parties has been provided. To wit, the petition commencing the case attached a notice of deficiency for the taxable year 2019 issued solely to petitioner Margaret R. Spencer. The answer also indicated that a jurisdictional motion might be forthcoming as to Paul K. Davidson, but nothing further has been received.
Accordingly, upon due consideration, it is
ORDERED that, on or before December 27, 2023, respondent shall file either: (1)An appropriate jurisdictional motion as to Paul K. Davidson; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Paul K. Davidson and attaching thereto a copy of any supporting documentation.