Opinion
14813-22S
01-30-2023
SALMA SAMAD & STEVEN SALCHAK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On July 4, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on August 17, 2022, 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 was 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 concerned the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods.
At that juncture, respondent was directed to supply pertinent materials, and respondent on January 27, 2023, filed a response attaching a notice of deficiency for 2018 issued to petitioner Salma Samad. Conversely, the response was silent as to petitioner Steven Salchak.
Accordingly, upon due consideration, it is
ORDERED that, on or before February 17, 2023, respondent shall file either: (1) An appropriate jurisdictional motion as to Steven Salchak; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Steven Salchak and attaching thereto a copy of any supporting documentation.