Opinion
8288-20
06-17-2021
Jose Cardenas Loeza Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On July 10, 2020, a petition was filed commencing the above-docketed matter, which petition was followed on October 23, 2020, by respondent's answer thereto. However, upon further review, it has come to the Court's attention that although the pleadings may purport to reference the notice or notices of deficiency or determination upon which this litigation is based, no complete copy of such notice(s) has been provided. A recent Motion for Continuance likewise highlighted ongoing research for jurisdictional documentation.
Accordingly, to clarify the record herein insofar as concerns documentation relevant to the Court's jurisdiction over any potential parties and taxable periods, it is
ORDERED that, on or before July 16, 2021, 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.
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