Opinion
7447-23P
07-11-2023
LUAN K. NGUYEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 23, 2023, respondent filed a Motion to Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted.
Upon due consideration, it is
ORDERED that, on or before August 2, 2023, petitioner shall file an Objection, if any, to respondent's above-referenced motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case. It is further
ORDERED that, on or before August 2, 2023, petitioner may file an amended petition. Petitioner is advised that the amended petition should contain clear and concise assignments of each and every error that petitioner alleges the Commissioner to have committed in the notice of certification of your seriously delinquent federal tax debt to the Department of State issued to petitioner for the 2007 tax year. Further, the amended petition should contain 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). The Tax Court Rules of Practice and Procedure are available on the Court's website at https://ustaxcourt.gov/rules.html.