Opinion
29868-21
03-30-2022
ALPESHKUMAR PATEL & PINAL PATEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
On March 3, 2022, respondent filed in the above-docketed matter a Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c) of the Tax Court Rules of Practice and Procedure. By Order dated March 9, 2022, the Court afforded petitioners an opportunity to file the delinquent reply to respondent's answer on or before April 5, 2022. The Order advised petitioners that respondent's motion would be denied if such reply as required by Rule 37(a) and (b) was filed and that the motion would be granted if such reply was not filed as directed. Petitioners so filed a reply on March 25, 2022.
Accordingly, the premises considered, it is
ORDERED that respondent's just-referenced March 3, 2022, motion is denied.