Opinion
4331-18
03-16-2022
Betty Amos Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Patrick J. Urda Judge
This case was tried on October 21, 2021, at the Court's remote trial session for cases associated with Atlanta, Georgia. At the conclusion of trial, the parties agreed to follow a simultaneous briefing schedule for their posttrial briefs. [Doc. 42 at 157.] Both parties timely submitted their opening and answering briefs.
Petitioner, Betty Amos, now moves for leave to file a reply to the Commissioner's simultaneous answering brief, arguing that the Commissioner raised numerous arguments in that brief that he had not previously made. Ms. Amos does not identify with any specificity which arguments or issues she finds objectionable. In any event, our review indicates that the Commissioner's arguments in his answering brief did not introduce new matters, but instead addressed positions previously taken by the Commissioner and Ms. Amos's own arguments. It is therefore
ORDERED that Ms. Amos's motion for leave to file reply to simultaneous answering brief, filed March 8, 2022, is denied.