Opinion
36261-21
02-23-2022
Philip Grippaldi & Lisa Grippaldi Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
Upon due consideration of the petition filed in this case and respondent's Motion To Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, filed February 18, 2022, it is
ORDERED that, on or before March 22, 2022, petitioners shall file an Objection, if any, to respondent's Motion To Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted. It is further
ORDERED that, on or before March 22, 2022, petitioners may file a proper amended petition that contains clear and concise assignments of each and every error that petitioner alleges to have been committed by the Commissioner in the determination of the deficiency and the penalty in dispute in this case, and clear and concise lettered statements of the facts on which petitioners bases the assignments of error. See Rule 34(b), Tax Court Rules of Practice and Procedure; Jarvis v. Commissioner, 78 T.C. 646, 658 (1982). 1