Opinion
6462-24
07-01-2024
DENNIS HIPSLEY & CAROL B. HIPSLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 6, 2024, respondent filed a Motion to Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted.
Upon due consideration, it is
ORDERED that, on or before July 22, 2024, petitioners shall file an Objection, if any, to respondent's above-referenced motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case. It is further
ORDERED that, on or before July 22, 2024, petitioner may file an amended petition. Petitioner is advised that the amended petition should contain clear and concise assignments of each and every error that petitioner alleges the Commissioner to have committed in the notice of determination concerning collection action issued to petitioners. Further, the 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). The Tax Court Rules of Practice and Procedure are available on the Court's website at https://ustaxcourt.gov/rules.html.
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