Opinion
28897-10 5816-11 5817-11
12-12-2022
HARVEY BIRDMAN & DIANE BIRDMAN, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
PATRICK J. URDA JUDGE
On October 18, 2022, petitioners Harvey and Diane Birdman filed a motion for reconsideration of our order served October 11, 2022, denying the Birdmans' motion for a jury trial and motion for oral argument. [Doc. 123.] The Birdmans also moved, in the alternative, for leave to file an interlocutory appeal. [Id.] The Commissioner subsequently filed a response [Doc. 129], followed by a reply from the Birdmans [Doc. 132]. After due consideration of the parties' arguments, it is
ORDERED that the Birdmans' motion for reconsideration of order is denied in so much as it pertains to the reconsideration of the Court's Order served October 11, 2022. It is further
ORDERED that the Birdmans' motion for reconsideration of order is denied in so much as it pertains to the request for leave to file an interlocutory appeal.