Opinion
13214-20
07-22-2022
STANLEY G. MILLER, DECEASED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Upon due consideration of respondent's Status Report, filed July 11, 2022, and the First Supplement thereto, filed July 20, 2022, it is
ORDERED that, on the Court's own motion, the Estate of Stanley G. Miller, Deceased, Christopher Johnsen, Administrator, is substituted for petitioner Stanley G. Miller, Deceased, in this case. It is further
ORDERED that the caption of this case is amended to read: "Estate of Stanley G. Miller, Deceased, Christopher Johnsen, Administrator, Petitioner(s) v. Commissioner of Internal Revenue, Respondent." It is further
ORDERED that, on or before September 20, 2022, petitioner shall file a proper amended petition in this case. Failure to file a proper amended petition on or before the aforementioned date may result in the dismissal of this case or other appropriate action by the Court. It is further
ORDERED that the Clerk of the Court shall attach to the copy of this Order served on petitioner an amended petition form that petitioner may use to comply therewith. It is further
ORDERED that, on or before September 20, 2022, petitioner shall pay the Court's filing fee of $60.00. Information on how to pay the filing fee is available at www.ustaxcourt.gov/pay_filing_fee.html. Waiver of the filing fee requires an affidavit or declaration containing specific financial information regarding the inability to make such payment. An Application for Waiver of Filing Fee form is available under "Case Related Forms" on the Court's website at www.ustaxcourt.gov/case_related_forms.html. The Court will consider whether to waive the filing fee upon receipt of such information from petitioner. Failure to pay the Court's $60.00 filing fee or submit an Application for Waiver of Filing Fee on or before the aforementioned date may result in the dismissal of this case or other appropriate action by the Court.
AMENDED PETITION
[ ] Please check the appropriate box(es) to show which IRS NOTICE(s) you dispute:
[ ] Notice of Deficiency
[ ] Determination of Worker Classification*
[ ] Notice of Determination Concerning Collection Action
[ ] Notice of Determination Concerning Your Request for Relief From Joint and Several Liability.
[ ] Notice of Final Determination Not to Abate Interest*
*Please see the Court's Web site, www.ustaxcourt.gov, or information booklet for additional information if (1) you filed a claim for interest abatement or requested relief from joint and several liability, and the IRS has not made a determination, or (2) the petition involves a worker classification case.
2. Provide the date(s) the IRS issued the NOTICE(S) checked above and the city and State of the IRS office(s) issuing the NOTICE(S): ______________
3. Provide the year(s) or period(s) for which the NOTICE(S) was/were issued: _________________________________
4. SELECT ONE OF THE FOLLOWING:
If you want your case conducted under small tax case procedures, check here: [ ] (CHECK
If you want your case conducted under regular tax case procedures, check here: [ ] ONEBOX)
NOTE: A decision in a "small tax case" cannot be appealed to a Court of Appeals by the taxpayer or the IRS.
If you do not check either box, the Court will file your case as a regular tax case.
5. Explain why you disagree with the IRS determination in this case (please list each point separately): ___________________________________
6. State the facts upon which you rely (please list each point separately): _____________________________________
You may use additional pages to explain why you disagree with the IRS determination or to state additional facts. Please do not submit tax forms, receipts, or other types of evidence with this petition.
ENCLOSURES:
Please check the appropriate boxes to show that you have enclosed the following items with this petition:
[ ] A copy of any NOTICE(S) the IRS issued to you D Statement of Taxpayer Identification Number (Form 4) (See PRIVACY NOTICE below)
[ ] The Request for Place of Trial (Fon-n 5)
[ ] The filing fee
PRIVACY NOTICE: Form 4 (Statement of Taxpayer Identification Number) will not be part of the Court's public files. All other documents filed with the Court, including this Petition and any IRS Notice that you enclose with this Petition, will become part of the Court's public files. To protect your privacy, you are strongly encouraged to omit or remove from this Petition, from any enclosed IRS Notice, and from any other document (other than Form 4) your taxpayer identification number (e.g., your Social Security number) and certain other confidential information as specified in the Tax Court's "Notice Regarding Privacy and Public Access to Case Files", available at www, ustaxcourt. gov.