Opinion
26640-22
02-28-2023
ALEXANDER GONZALEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN, CHIEF JUDGE
On November 28, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on February 1, 2023, 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 was 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 27, 2023, respondent filed an initial report indicating that additional time was needed. Accordingly, upon due consideration, it is
ORDERED that, on or before April 28, 2023, 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.