Opinion
4663-23P
05-18-2023
SCOTT M. FOX & RACHEL L. FOX, Petitioners 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 May 17, 2023, in the above-docketed case, it is
ORDERED that petitioners shall, on or before June 8, 2023, file an objection, if any, to respondent's just-referenced motion. It is further
ORDERED that, on or before June 8, 2023, petitioner may file with the Court a proper Second Amended Petition that sets forth clear and concise assignments of each and every error that petitioners allege to have been committed by the Commissioner in the Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the State Department in dispute in this case, and clear and concise lettered statements of the facts on which petitioners base the assignments of error. See Rules 34(b), 351(b), Tax Court Rules of Practice and Procedure; Jarvis v. Commissioner, 78 T.C. 646, 658 (1982).