Opinion
37883-21
03-11-2022
Marcellus Lamarr Gregory & Carolyn Gregory Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On March 10, 2022, respondent filed in the above-docketed matter a Motion for More Definite Statement Pursuant to Rule 51 of the Tax Court Rules of Practice and Procedure. Upon due consideration, it is
ORDERED that respondent's just-referenced Motion for More Definite Statement Pursuant to Rule 51 is granted. It is further
ORDERED that petitioners shall, on or before April 11, 2022, file with the Court a proper amended petition and shall include therein (1) the date of the notice(s) of deficiency or determination being disputed and the taxable year(s) for which such notice(s) was/were issued; (2) clear and concise lettered assignments of each and every error petitioners allege was committed by respondent (i.e., the Internal Revenue Service (IRS)) in the notice(s) of deficiency or determination underlying this proceeding; and (3) clear and concise lettered statements of every fact upon which petitioners base each assignment of error. See Rules 34(b)(4) and (5), 331(b)(4) and (5), Tax Court Rules of Practice and Procedure. It is further
ORDERED that petitioners shall attach to the amended petition a copy of each notice upon which petitioners rely to establish the jurisdiction of the Court over this proceeding.