Opinion
15753-23
04-15-2024
SHIRLEY R. COOLEY & GARY A. COOLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 12, 2024, 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.
Upon due consideration, it is
ORDERED that, on or before May 6, 2024, petitioners shall file a reply, if any, to the answer in accordance with Rule 37(a) and (b) of this Court's Rules. The Court advises that respondent's just-referenced motion will be denied if such reply is filed as directed. Conversely, the motion will be granted if such reply is not filed as directed, thereby deeming admitted for purposes of this case the affirmative allegations set forth in the answer.