Opinion
22523-22
02-22-2023
MOHAMMAD M. MASSOUDI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 23, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on December 9, 2022, by respondent's answer thereto. However, upon further review, it came to the Court's attention that although the pleadings might reference the notice or notices of deficiency or determination upon which this litigation was based, no complete copy of such notice(s) had been provided. It was therefore advisable to ensure that the record herein was complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods, and respondent was directed to file appropriate materials.
Subsequently, on February 17, 2023, respondent filed an initial report indicating that additional time was needed. Accordingly, upon due consideration, it is
ORDERED that, on or before April 21, 2023, respondent shall file a further report or response and shall attach thereto a complete copy of the notice of deficiency for 2017 issued to petitioner.