Opinion
9750-22
07-28-2022
RAJENDRA RAI & DHAN M. RAI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 15, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on June 22, 2022, by respondent's answer thereto. However, upon further review, it came to the Court's attention that although the pleadings may 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. It was therefore advisable to ensure that the record herein was complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods, and respondent was directed to file appropriate materials.
Subsequently, on July 20, 2022, respondent filed an initial report indicating that additional time was needed. Accordingly, upon due consideration, it is
ORDERED that, on or before September 26, 2022, respondent shall file either: (1) An appropriate jurisdictional motion; and/or (2) a further report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation.