Opinion
31331-21
01-13-2022
Michael C. Robinson 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 January 10, 2022, it is
ORDERED that, on or before February 9, 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 February 9, 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 deficiencies and the additions to tax 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).