Opinion
29295-21
03-24-2022
Earl C. Ogden Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of the petition filed in this case and respondent's Motion To Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, filed March 3, 2022, it is
ORDERED that, on or before April 12, 2022, petitioner shall file an Objection, if any, to respondent's Motion To Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted. It is further
ORDERED that, on or before April 12, 2022, petitioner may file a proper amended petition that contains clear and concise assignments of each and every error that petitioner alleges to have been committed by the Commissioner in the determination of the deficiency and the penalty in dispute in this case, and clear and concise lettered statements of the facts on which petitioners 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).