Opinion
1370-23
10-05-2023
SEAN E. TALAEE & JUDY A. GREGORY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 15, 2023, 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 served August 16, 2023, the Court afforded petitioners an opportunity to file the delinquent reply to respondent's Answer to Amendment to Petition on or before September 13, 2023. 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. No reply has been received from petitioners. Accordingly, the premises considered, it is
ORDERED that respondent's just-referenced August 15, 2023, motion is granted, and the allegations set forth in paragraphs 11 and 12 of respondent's Answer to Amendment to Petition are hereby deemed admitted.