Opinion
14994-23
04-15-2024
ORDER
Kathleen Kerrigan, Chief Judge
Upon due consideration of respondent's Motion for Entry of Order That Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c), filed April 12, 2024, it is
ORDERED that, on or before May 31, 2024, petitioners shall file a reply to the affirmative allegations set out in paragraphs 8 through 34 of respondent's Answer, filed January 18, 2024. In accordance with Rule 37(b) of the Tax Court Rules of Practice and Procedure, any such reply shall contain a specific admission, denial, or claim of lack of information with respect to each of the affirmative allegations. Failure to file such a reply may result in the granting of respondent's above-referenced Motion and the deemed admission of the affirmative allegations for purposes of this case.