Opinion
22500-21
12-16-2021
Michael J. Miller & Wendy A. Miller Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On June 21, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on November 5, 2021, by respondent's answer thereto. However, upon further review, it came 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) had been provided. Thereafter, on December 10. 2021, respondent filed a status report advising that research in such regard was ongoing.
Accordingly, upon due consideration, it is
ORDERED that the time within which 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, is hereby extended to January 14, 2022.