Opinion
4093-23
04-24-2023
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion To Dismiss for Failure To State a Claim Upon Which Relief Can Be Granted, filed April 20, 2023, in the above-docketed case, it is
ORDERED that petitioners shall, on or before May 22, 2023, file an objection, if any, to respondent's just-referenced motion. It is further
ORDERED that, on or before May 22, 2023, petitioners may file with the Court a proper amended petition that sets forth clear and concise assignments of each and every error that petitioners allege to have been committed by the Commissioner in the determination of the deficiencies, additions to tax, and/or penalties in dispute in this case, and clear and concise lettered statements of the facts on which petitioners base the assignments of error. See Rule 34(b), Tax Court Rules of Practice and Procedure; Jarvis v. Commissioner, 78 T.C. 646, 658 (1982).
ORDERED that the time within which petitioners shall pay the Court's $60.00 filing fee (or submit an Application for Waiver of Filing Fee form, which is available under the "eFiling & Case Maintenance" tab on the Court's website, www.ustaxcourt.gov), is extended to May 22, 2023. If the filing fee (or proper application for waiver) is not received by that date, the Court may dismiss this case for lack of jurisdiction.