Opinion
21904-19
10-05-2021
Hong Jun Chan & Suzhen Mei Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Albert G. Lauber, Judge
This case was originally calendared on the Court's October 4, 2021, Los Angeles, California, trial session. On July 2, 2021, respondent filed a motion for summary judgment. We ordered petitioners to respond to that motion by August 9, 2021. When petitioners did not respond by that date, we struck the case from the October 4 trial session and retained jurisdiction to decide respondent's motion. On October 3, 2021, the Court received a document from petitioners that is captioned "Answer to Supplement to Petition," plus three "Declarations."
In consideration of the foregoing, it is
ORDERED that petitioners' "Answer to Supplement to Petition," filed October 3, 2021, at docket entry #20, is recharacterized as petitioners' Response to Motion for Summary Judgment. It is further
ORDERED that petitioners' Declarations, filed October 3, 2021, at docket entries ## 21, 22, and 23, are recharacterized as petitioners' Exhibits in Support of Response to Motion for Summary Judgment. It is further
ORDERED that respondent shall file with the Court, on or before November 5, 2021, a reply to petitioners' Response.
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