Opinion
30698-21
01-07-2022
Derrell J. Fulton & Jaquan D. Gilbert Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of respondent's Motion To Dismiss for Failure To State a Claim Upon Which Relief Can Be Granted, filed January 5, 2022, in the above-docketed case, it is
ORDERED that petitioners shall, on or before January 26, 2022, file an objection, if any, to respondent's just-referenced motion. It is further
ORDERED that, on or before January 26, 2022, petitioners may file with the Court a proper 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 determination of the deficiencies, additions to tax, and/or penalties in dispute in this case, and clear and concise lettered statements of the facts on which petitioners base the assignments of error. See Rule 34(b), Tax Court Rules of Practice and Procedure; Jarvis v. Commissioner, 78 T.C. 646, 658 (1982).