Opinion
17670-21S
11-29-2021
Cristian Marinescu & Emma Hart Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On May 17, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on July 7, 2021, by a first amended petition, and on September 7, 2021, by respondent's answer. However, upon further review, it has come to the Court's attention that although the pleadings may 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. It is therefore advisable to ensure that the record herein is complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods. Additionally, a letter from petitioners suggests that the matter may have been resolved administratively, so an appropriate basis for closure may be relevant in due course.
Accordingly, upon due consideration, it is
ORDERED that, on or before December 15, 2021, respondent shall file a report and shall attach thereto a complete copy of the notice of deficiency for 2017 issued to petitioners.