Opinion
25461-16 12178-17 12179-17 22725-17 5729-18 11882-18 15581-18 6898-19 2373-23 5689-23.
07-08-2024
DESMOND MCGUIRE & CORY LYNNE BRAME, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch, Judge.
Pending before the Court is the Commissioner's Motion to Review the Sufficiency of Answers or Objections to Request for Admissions filed July 3, 2024. On February 9, 2024, the Commissioner served on petitioners a First Request for Admissions consisting of 312 numbered admissions. On March 11, 2024, petitioners responded. That response included the following response to several of the requests: "Deny, Petitioners have not had enough time to review this request and will supplement a response upon review." Petitioners later filed a First Supplement to Response to First Request for Admissions, but that supplement did not address all of the unanswered requests. On July 3, 2024, the Commissioner filed a Motion to Review the Sufficiency of Answers or Objections to Request for Admissions specifically directed at requests 270, 275, 277, 280, 281, and 284. Petitioner had denied each of those requests as quoted above but had not supplement those responses. Five hours later, petitioners filed a Second Supplement to Response to First Request for Admissions in which they addressed each the requested numbered above.
Petitioners' responses to requests 275 and 280 fall short of the standard exemplified by their other responses. Petitioners' responses to requests 270, 277, 281, and 284 specify what petitioners are denying and qualify the remainder. For requests, 275 and 280, however, petitioners provide only a bare denial. Accordingly, it is
ORDERED that the Commissioner's Motion to Review the Sufficiency of Answers or Objections to Request for Admissions filed July 3, 2024, is granted. It is further
ORDERED that by July 19, 2024, petitioners shall supplement their responses to requests 275 and 280, specifying as much of those requests as are true and denying or qualifying the remainder.