Opinion
22732-19
07-25-2022
JAMES P. CARNEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
On July 20, 2022, the Commissioner filed an objection to the motion for depositions under Rule 81, and filed a declaration in support of the motion. It would be helpful to the Court to have a reply from petitioner James P. Carney. Therefore it is
ORDERED that, on or before August 5, 2022, Mr. Carney shall file a reply to the Commissioner's objection to the motion for depositions under Rule 81. Specifically, Mr. Carney shall address the Commissioner's argument on pages 9- 17 of the objection to the motion for depositions under Rule 81, that it is impractical to take depositions in either Portugal or Greece.