Opinion
9953-21
08-03-2021
Nick A. Kolev Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of respondent's Motion To Dismiss for Failure To State a Claim Upon Which Relief Can Be Granted and To Impose a Penalty Under I.R.C. 6673, filed July 16, 2021, in the above-docketed case, it is
ORDERED that the motion shall be recharacterized to correct the cover page to reflect the full title as a Motion To Dismiss for Failure To State a Claim Upon Which Relief Can Be Granted and To Impose a Penalty Under I.R.C. 6673. It is further
ORDERED that petitioner shall, on or before August 31, 2021, file an objection, if any, to respondent's just-referenced motion. It is further
ORDERED that, on or before August 31, 2021, petitioner may file with the Court a proper amended petition that sets forth clear and concise assignments of each and every error that petitioner alleges to have been committed by the Commissioner in the determination of the deficiencies, additions to tax, and/or penalties in dispute in this case, and clear and concise lettered statements of the facts on which petitioner 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).