Opinion
27013-22
02-07-2023
JAMES SMITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On February 3, 2023, respondent filed in the above-docketed matter a Motion for More Definite Statement Pursuant to Rule 51 of the Tax Court Rules of Practice and Procedure. Upon due consideration, it is
ORDERED that respondent's just-referenced Motion for More Definite Statement Pursuant to Rule 51 is granted in that it is further
ORDERED that petitioner shall, on or before March 6, 2023, file with the Court a proper amended petition and shall include therein (1) the date of the notice(s) of deficiency or determination being disputed and the taxable year(s) for which such notice(s) was/were issued; (2) clear and concise lettered assignments of each and every error petitioner alleges was committed by respondent (i.e., the Internal Revenue Service (IRS)) in the notice(s) of deficiency or determination underlying this proceeding; and (3) clear and concise lettered statements of every fact upon which petitioner bases each assignment of error. See Rules 34(b)(4) and (5), 331(b)(4) and (5), Tax Court Rules of Practice and Procedure. It is further
ORDERED that petitioner shall attach to the amended petition a copy of each notice upon which petitioner relies to establish the jurisdiction of the Court over this proceeding.