Opinion
3876-22
03-24-2022
Daryl W. Earls & Kathy L. Earls Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge.
Upon due consideration of the petition filed in this case and respondent's Motion To Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, filed March 21, 2022, it is
ORDERED that, on or before April 18, 2022, petitioners shall file an Objection, if any, to respondent's Motion To Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted. It is further
ORDERED that, on or before April 18, 2022, petitioners may file a proper amended petition that contains clear and concise assignments of each and every error that petitioners allege to have been committed by the Commissioner in the determination of the deficiency in dispute in this case, and clear and concise lettered statements of the facts on which petitioner bases the assignments of error. See Rule 34(b), Tax Court Rules of Practice and Procedure; Jarvis v. Commissioner, 78 T.C. 646, 658 (1982). 1