Opinion
6850-23
06-08-2023
SAMUEL ALLEN FINCK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion To Dismiss for Failure To State a Claim Upon Which Relief Can Be Granted, filed June 7, 2023, in the above-docketed case, it is
ORDERED that petitioner shall, on or before July 5, 2023, file an objection, if any, to respondent's just-referenced motion. It is further
ORDERED that, on or before July 5, 2023, petitioner may file with the Court a proper amended petition that sets forth clear and concise assignments of each and every error that petitioner alleges to have been committed by the Commissioner in the determination of the deficiencies, additions to tax, and/or penalties in dispute in this case, and/or the determination regarding any collection action in dispute in this case, and clear and concise lettered statements of the facts on which petitioner bases the assignments of error. See Rules 34(b), 331(b), Tax Court Rules of Practice and Procedure; Jarvis v. Commissioner, 78 T.C. 646, 658 (1982).