Opinion
24917-22
03-06-2023
MOHAMMAD K. THABET & WAFA TOSTOUK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On January 20, 2023, petitioners filed a First Amended Petition. Petitioners' Amended Petition is untimely and was not accompanied by a motion for leave. See 41(a), Tax Court Rules of Practice and Procedure. The Court will recharacterize the First Amended Petition as a Motion for Leave to File Amended Petition (Embodying Amended Petition).
Upon due consideration, it is
ORDERED that petitioners' First Amended Petition is recharacterized as a Motion for Leave to File First Amended Petition (Embodying Amended Petition). It is further
ORDERED that, on or before March 27, 2023, respondent shall file an objection, if any, to the above-described motion for leave.