Opinion
13420-20
12-28-2021
Jennifer Ann Hnatowski Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On December 28, 2020, a petition was filed commencing the above-docketed matter, which petition was followed on February 17, 2021, by respondent's answer thereto. However, upon further review, it came 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 copy of such notice(s) had 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. At that juncture, the Court directed respondent to file an appropriate motion or report, but such has not occurred.
Accordingly, upon due consideration, it is
ORDERED that the time within which respondent shall file either: (1) An appropriate jurisdictional motion, and/or (2) a report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation, is hereby extended to January 14, 2022.