Opinion
20692-20
01-06-2022
Johan Alar Grate & Lemonda Bynoe 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 October 13, 2021, it is
ORDERED that, on or before January 28, 2022, petitioners shall file an Objection, if any, to respondent's above-referenced motion. It is further
ORDERED that, on or before January 28, 2022, petitioners may file a proper amended petition. Petitioners are advised that the amended petition should contain clear and concise assignments of each and every error that petitioner alleges the Commissioner to have committed. Further, that amended petition should contain 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). It is further
ORDERED that the Clerk of the Court shall attach to this Order served on petitioners a form which petitioners may use for purposes of filing a proper amended petition.