Opinion
17038-18L 17535-18L
08-27-2024
THE DIVERSIFIED GROUP INCORPORATED, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro, Judge
On April 14, 2022, respondent filed a Motion for Partial Summary Judgment along with a Declaration of Brooke N. Stan. On March 11, 2024, petitioners filed a Response to Motion for Partial Summary Judgment along with a Declaration of Henry John Huber, Jr. and a Declaration of Jasper G. Taylor III. On June 24, 2024, respondent filed a Reply to Petitioners' Response along with a Supplemental Declaration of Brooke N. Stan. On August 13, 2024, petitioners filed a Sur-Reply.
On August 26, 2024, respondent filed a Motion for Leave to File Response to Petitioners' Sur-Reply. Respondent "seeks leave to respond to Petitioners' Sur-Reply to discuss Respondent's position as to the effect of Loper Bright Enterprises on this case."
Upon due consideration, it is hereby
ORDERED that respondent's Motion for Leave to File Response to Petitioners' Sur-Reply is granted in that on or before September 17, 2024, respondent shall file his Response. The Response shall be limited to the issue identified in paragraph four of respondent's Motion for Leave to File Response to Petitioners' Sur-Reply. It is further
ORDERED that, no later than 21 days after the filing of respondent's Response, petitioners may file a Reply.