Opinion
16850-22S
09-28-2022
ADOLFO SANDOVAL, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 1, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on September 21, 2022, by respondent's answer thereto. However, upon further review, it has come 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) has been provided. 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 October 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.