Opinion
3412-24
05-30-2024
LAWRENCE FEIGENBAUM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On February 26, 2024, correspondence from or on behalf of petitioner, not accompanied by payment of the Court's filing fee, was filed as an imperfect petition to commence the above-docketed case. By Order served February 29, 2024, the Court directed petitioner to file an Amended Petition and to pay the Court's $60.00 filing fee. On April 2, 2024, petitioner filed a First Amendment to Petition and also paid the filing fee. However, petitioner's amendment was merely a petition form with petitioner's name, the docket number, notice of deficiency checked, and petitioner's signature. The petition failed to state what year the notice of deficiency was issued for, explain why petitioner disagreed with the notice of deficiency, or state the facts on which he relied.
At that juncture, the Court by Order served April 17, 2024, directed petitioner to file a further Amendment to Petition that stated the year of the notice of deficiency and contained clear and concise assignments of each and every error which petitioner alleged the Commissioner committed in the determination of the deficiency and specific statements of facts on which he based those assignments of error. See Rule 34(b), Tax Court Rules of Practice and Procedure. However, nothing additional has been received from petitioner.
In view of the foregoing, it is
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction on the ground that petitioner failed to file a proper Amendment to Petition. It is further
ORDERED that petitioner's Motion To Proceed Remotely, filed April 2, 2024, is denied as moot.