Opinion
11937-22
03-16-2023
ROBIN J. REYNOLDS & ROSSILENE P. REYNOLDS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 18, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on July 19, 2022, by respondent's answer thereto. However, upon further review, it has come to the Court's attention that the petition commencing the case attached a notice of deficiency for the taxable year 2018 issued solely to petitioner Robin J. Reynolds. It is therefore advisable to ensure that the record herein is complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods.
Accordingly, upon due consideration, it is
ORDERED that, on or before April 7, 2023, respondent shall file either: (1) An appropriate jurisdictional motion as to Rossilene P. Reynolds; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Rossilene P. Reynolds and attaching thereto a copy of any supporting documentation.