Opinion
5952-22
08-09-2022
TODD LAROCHE & DANIELLE R. USEWICZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo Chief Special Trial Judge
Although the petition is not as complete as we would like, the allegations in the petition show that petitioner is challenging the deficiency in his 2019 Federal income tax determined in the notice of deficiency issued to him on February 7, 2022, at least a part of which is attached to the petition. That being so, it is
ORDERED that respondent's motion to dismiss for failure to state a claim upon which relief can be granted, filed May 17, 2022, is denied.