Opinion
7343-22L
10-21-2022
ALEXANDRINO S. SILVA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge
This case is calendared for trial at the Court's January 30, 2023, Miami, Florida trial session. On October 13, 2022, the Commissioner filed a Motion for Entry of Order that Undenied Allegations be Deemed Admitted Pursuant to Rule 37(c). Those allegations are contained in paragraphs 8(a) through (h) of the Commissioner's First Amended Answer. Many of those allegations are legal conclusions; we will deem the factual allegations as admitted. Accordingly, it is
ORDERED that the Commissioner's Motion for Entry of Order that Undenied Allegations be Deemed Admitted Pursuant to Rule 37(c) is granted in that paragraphs 8(a) and 8(e) of the Commissioner's First Amended Answer filed August 18, 2022, are deemed admitted.