Opinion
9084-22
08-03-2022
NANCY EGEA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On April 18, 2022, petitioner filed a Petition seeking review of a Notice of Deficiency issued to petitioner on March 28, 2022, with respect to her Federal income tax for the 2019 taxable year. On June 21, 2022, respondent filed an Answer.
On June 24, 2022, petitioner filed a First Amended Petition. Therein, petitioner continues to seek review of the aforementioned Notice of Deficiency issued to her for the 2019 taxable year; however, in addition petitioner appears to seek review of a notice of deficiency purportedly issued to her for the 2018 taxable year. There does not appear to be any such notice attached to the First Amended Petition.
Upon due consideration and for cause, it is
ORDERED that petitioner's First Amended Petition is recharacterized as petitioner's Motion for Leave to File First Amended Petition (Embodying First Amended Petition). It is further
ORDERED that petitioner's Motion for Leave to File First Amended Petition (Embodying First Amended Petition), filed June 24, 2022, is granted nunc pro tunc, and the First Amended Petition is filed as of such date. It is further
ORDERED that respondent shall have until September 2, 2022, within which to file answer or to move with respect to petitioner's First Amended Petition. Respondent shall attach to such filing the notice of deficiency, if any, issued to petitioner for the 2018 taxable year.