Opinion
3157-23L
01-25-2024
CARLOS A. PONS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On March 12, 2023, petitioner filed the petition. On April 27, 2023, respondent filed the Answer, in which respondent made affirmative allegations in paragraphs 8 and 9. On July 21, 2023, respondent filed a Motion for Entry of Order that Undenied Allegations be Deemed Admitted Pursuant to Rule 37(c). By Order served August 1, 2023, the Court directed petitioner to file a Reply. On August 21, 2023, petitioner filed a Reply, which fails to address the affirmative allegations in respondent's Answer.
Upon due consideration, it is
ORDERED that, on or before April 1, 2024, petitioner shall file an Amended Reply. If petitioner fails to file an Amended Reply in accordance with Rule 37 by April 1, 2024, that addresses the affirmative allegations made by respondent in paragraphs 8 and 9 of the Answer, the Court may grant respondent's motion and deem the affirmative allegations in the Answer admitted by petitioner.