Opinion
19798-23S
01-19-2024
RACHAEL LOPEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 17, 2024, respondent filed in the above-docketed matter a Motion for More Definite Statement Pursuant to Rule 51 of the Tax Court Rules of Practice and Procedure.
Upon due consideration, it is
ORDERED that respondent's just-referenced Motion for More Definite Statement Pursuant to Rule 51 is granted. It is further
ORDERED that, on or before February 12, 2024, petitioner shall file with the Court a proper amended petition, which shall include (1) clear and concise lettered assignments of each and every error petitioner alleges was committed by respondent (i.e., the Internal Revenue Service (IRS)) in the notice(s) of deficiency or determination underlying this proceeding; and (2) clear and concise lettered statements of every fact upon which petitioner bases each assignment of error. See Rules 34(b)(4) and (5), 331(b)(4) and (5), Tax Court Rules of Practice and Procedure.