Opinion
30616-21P
12-23-2021
John F. Pavel 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 December 21, 2021, it is
ORDERED that, on or before January 21, 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 January 21, 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 certifying petitioner as an individual owing a seriously delinquent tax debt, and clear and concise lettered statements of the facts on which petitioner bases the assignments of error.