Opinion
30163-21
04-21-2022
THOMAS D. WOLSEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MAURICE B. FOLEY, CHIEF JUDGE
Upon due consideration of the Motion To Dismiss for Lack of Jurisdiction as to 2017, filed February 16, 2022, by respondent in the above-docketed case, and the complete record herein, it is
ORDERED that, on or before June 3, 2022, petitioner shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion and partial dismissal of the instant case as to 2017 or other appropriate action by this Court. The case as to 2018 is not affected by respondent's motion and will continue before the Court, provided petitioner files a Ratification of Amended Petition bearing his original signature. It is further
ORDERED that the time within which petitioner shall file with the Court a Ratification of Amended Petition, bearing petitioner's original signature (preferably in blue ink), in which petitioner states, if such be the case, that petitioner has read the Amended Petition filed December 22, 2021, and ratifies and affirms the filing of said document, is hereby extended to June 3, 2022. If no such Ratification of Amended Petition is received by that date, the Court may dismiss this case for lack of jurisdiction. Petitioner should note that the Ratification of Amended Petition may NOT be filed electronically, and the Tax Court, unlike the Internal Revenue Service (IRS), does NOT recognize powers of attorney. The Ratification of Amended Petition should be a separate document from any objection to the pending motion. It is further
ORDERED that the place of trial for any proceedings in this case shall be changed to San Diego, California. The parties are reminded, however, that trial will only be held if the case is not otherwise dismissed or resolved.