Opinion
3370-23
08-16-2023
BRUCE D. ALLEN & JULIE M. ALLEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 24, 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 issued July 25, 2023, the Court afforded petitioners an opportunity to file the delinquent reply to respondent's answer on or before August 15, 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. Petitioners so filed a reply on August 15, 2023. Accordingly, the premises considered, it is
ORDERED that respondent's just-referenced July 24, 2023, motion is denied.