Opinion
7101-22
04-29-2022
GRETCHEN L. PARKER, 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 April 18, 2022, it is
ORDERED that, on or before May 23, 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 May 23, 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 petitioner 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).