Opinion
26819-22L
08-24-2023
MARK LEONARD & DAWN LEONARD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 6, 2023, respondent filed a Motion for Entry of Order That Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c). By Order served July 10, 2023, the Court directed petitioners to file a Reply to the affirmative allegations in respondent's Answer on or before July 31, 2023. No Reply has been received from petitioners.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion for Entry of Order That Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c) is granted and undenied allegations in the Answer are deemed admitted by petitioners. See Rule 37(c), Tax Court Rules of Practice and Procedure.