Opinion
19714-16
12-16-2021
Clair R. Couturier, Jr. & Vicki Couturier Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
L. Paige Marvel, Judge
On August 27, 2021, petitioners filed a motion for summary judgment. On October 27, 2021, respondent filed his response to motion for summary judgment and three declarations: (1) declaration of James Szollosi in support of response to motion for summary judgment (2) declaration of Revenue Agent Penny Yung in support of response to motion for summary judgment and (3) declaration of Laura A. Price in support of response to motion for summary judgment. On December 13, 2021, petitioners filed a reply to response to motion for summary judgment and an objection to declaration of Laura A. Price in support of response to motion for summary judgment. On December 14, 2021, the Court issued an order directing respondent to file by January 14, 2022, a response to petitioners' objection to declaration of Laura A. Price in support of response to motion for summary judgment. On December 15, 2021, respondent filed an unopposed motion for leave to file sur-reply to response to motion for summary judgment (motion for leave to file sur-reply). In respondent's motion for leave to file sur-reply, respondent requests until January 28, 2022, to file his sur-reply, and respondent requests an extension of time to January 28, 2022, to file a response to petitioners' objection to declaration of Laura A. Price in support of response to motion for summary judgment..
After due consideration and for cause, it is
ORDERED that respondent's motion for leave to file sur-reply filed December 15, 2021, is granted in that respondent shall file his sur-reply to response to motion for summary judgment on or before January 28, 2022. It is further
ORDERED that time is extended from January 14, 2022, to January 28, 2022, for respondent to file a response to petitioners' objection to declaration of Laura A. Price in support of response to motion for summary judgment.