Opinion
31003-21
04-22-2022
MATHEW ALLEN EVANS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
On November 17, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on January 7, 2022, by respondent's answer thereto. However, upon further review, it came to the Court's attention that although the pleadings might reference the notice or notices of deficiency or determination upon which this litigation is based, no complete copy of such notice(s) had been provided. It was therefore advisable to ensure that the record herein was complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods, and respondent was directed to file appropriate materials. Subsequently, on February 16, 2022, respondent filed a report indicating that efforts to secure documentation remained ongoing.
Accordingly, upon due consideration, it is
ORDERED that, on or before May 20, 2022, respondent shall file either: (1) An appropriate jurisdictional motion; and/or (2) a further report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation.