Opinion
28215-14
03-29-2023
ALICE PERKINS & FREDRICK PERKINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's May 16, 2015 trial calendar for Buffalo, New York. The Court entered decision on May 30, 2019. The Second Circuit later affirmed the decision. On January 11, 2023 the Court received a motion for leave to amend the petition. Since we entered decision so long ago, this motion is improper without a suitable motion to vacate the decision. It is therefore
ORDERED that petitioners' January 11, 2023 motion for leave to amend is denied without prejudice should the Court vacate its decision in this case.