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Breland v. Comm'r of Internal Revenue

United States Tax Court
Sep 2, 2021
No. 21940-12 (U.S.T.C. Sep. 2, 2021)

Opinion

21940-12 22319-12

09-02-2021

Charles K. Breland, Jr. Et Al., Petitioner v. Commissioner of Internal Revenue, Respondent


ORDER

Cary Douglas Pugh, Judge

These cases are currently set for trial at the Court's November 29, 2021, Miami, Florida trial session, to be conducted remotely. On July 14, 2021, petitioners filed a Motion for Leave to Amend Petition, and lodged a First Amended Petition in docket no. 21940-12. By Order dated July 22, 2021, we directed respondent to file a response to petitioner's Motion for Leave to Amend Petition by August 20, 2021. On August 20, 2021 at 1:30pm, respondent filed a Motion for Extension of Time to file a response to petitioners' Motion for Leave to Amend Petition, to which petitioners did not object. The timing of respondent's motion implies a presumption that extension is automatic. We will grant the motion because petitioners did not object but we also caution against assuming that we will grant all requests for extension particularly ones filed at the very last minute. Upon due consideration and for cause, it is hereby

ORDERED that the time in which respondent has to file a response to petitioners' Motion for Leave to Amend Petition, filed July 14, 2021, at docket no. 21940-12, is extended to September 20, 2021.

Respondent is reminded that his response to petitioner's Motion for Leave to File First Amendment to Petition, filed July 30, 2021, in docket no. 22319-12, is due September 9, 2021.

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Summaries of

Breland v. Comm'r of Internal Revenue

United States Tax Court
Sep 2, 2021
No. 21940-12 (U.S.T.C. Sep. 2, 2021)
Case details for

Breland v. Comm'r of Internal Revenue

Case Details

Full title:Charles K. Breland, Jr. Et Al., Petitioner v. Commissioner of Internal…

Court:United States Tax Court

Date published: Sep 2, 2021

Citations

No. 21940-12 (U.S.T.C. Sep. 2, 2021)