Opinion
20882-21
10-04-2022
ALAN HAMEL & SUZANNE HAMEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi Special Trial Judge
Upon due consideration of respondent's Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c), filed January 26, 2022, it is
ORDERED that no later than November 1, 2022, petitioners shall file a reply, if any, to respondent's Answer, filed October 29, 2021. Any such reply shall comply with Rule 37(b) of the Tax Court Rules of Practice and Procedure. The Court advises that respondent's above referenced motion will be granted if such a reply is not filed as directed, thereby deeming admitted for purposes of this case the affirmative allegations set forth in the Answer.