Opinion
3770-22
04-26-2022
MOSHE HERZLICH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge
On February 2, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on April 21, 2021, by respondent's answer thereto. However, upon further review, it has come to the Court's attention that although the pleadings may reference the notice or notices of deficiency or determination upon which this litigation is based, no complete and dated copy of such notice(s) has been provided. It is therefore advisable to ensure that the record herein is complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods. Accordingly, upon due consideration, it is
ORDERED that, on or before May 25, 2022, respondent shall file a report and shall attach thereto a complete and dated copy of the notice of deficiency for 2018 and 2019 issued to petitioner or other proof of the mailing of the notice of deficiency.