Opinion
24344-17 11352-18 25268-18
03-24-2022
SUNIL S. PATEL & LAURIE MCANALLY PATEL, ET. AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
This consolidated case is scheduled for trial at a special session of the Court, to commence on April 25, 2022. On February 24, 2022, petitioners filed a motion to shift the burden of proof. On March 3, 2022, respondent filed an objection to petitioners' motion. On March 11, 2022, petitioners filed a reply to respondent's objection. On March 16, 2022, respondent filed a motion to strike petitioners' reply.
For the reasons set forth in respondent's objection and motion to strike, it is
ORDERED that respondent's motion to strike is granted and petitioners' reply, filed March 16, 2022, is hereby stricken from the record. It is further
ORDERED that petitioners' motion to shift the burden of proof, filed February 24, 2022, is denied. 1