Opinion
13520-23
09-29-2023
DAHLIA R. MINOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 27, 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. It is further
ORDERED that petitioner shall, on or before October 27, 2023, file with the Court a proper amended petition and shall include therein (1) 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 of deficiency underlying this proceeding; and (2) clear and concise lettered statements of every fact upon which petitioner bases each assignment of error. See Rule 34(b), Tax Court Rules of Practice and Procedure.