Opinion
17603-13 17614-13
09-28-2023
VINCENT J. FUMO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber, Judge
These cases were tried at a three-week special session in Philadelphia, Pennsylvania, from October 3 to 19, 2022. At the end of trial the Court set a briefing schedule. By Order served February 1, 2023, we granted the parties' joint Motion for Extension of Time to file their briefs. Respondent timely filed his Seriatim Opening Brief on March 27, 2023. By Order served May 26, 2023, we granted petitioner's unopposed Motion for Extension of Time to file his Seriatim Answering Brief by 90 days, to October 20, 2024.
On September 25, 2023, petitioner filed another Motion for Extension of Time requesting that the due dates for the parties' remaining briefs be extended by another 45 days. This is petitioner's third motion for an extension of time, and our granting it will have extended, by more than half a calendar year, the total time in which he has to file his Seriatim Answering Brief. We will afford petitioner an additional 45 days in which to file his Seriatim Answering Brief, but absent the most exceptional circumstances, no further extensions of time will be granted. Upon due consideration, it is
ORDERED that petitioner's Motion for Extension of Time, filed September 25, 2023, is granted in that the due dates for the parties' remaining briefs are extended to the following dates:
Petitioner's Seriatim Answering Brief: December 4, 2023
Respondent's Reply Brief: January 11, 2024
Petitioner's Sur-Reply Brief: February 9, 2024