Opinion
25763-21
04-19-2022
MADHU S. POTLA & JAYAPRADA POTLA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
On July 19, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on November 22, 2021, by respondent's answer thereto. However, upon further review, it came to the Court's attention that although the pleadings might 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. At that juncture, respondent was directed to file an appropriate motion or report to clarify the record and jurisdictional parameters.
Subsequently, on April 18, 2022, respondent filed a report requesting additional time to secure relevant materials. Accordingly, upon due consideration, it is
ORDERED that, on or before June 21, 2022, 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.