Opinion
25624-17 25668-17
03-30-2023
RICHARD T. DOAN, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph W. Nega, Judge..
Upon due consideration of petitioners' motion to dismiss for lack of prosecution and motion for summary judgment, both filed March 24, 2023, it is
ORDERED that petitioners' motion for summary judgment is denied. It is further
ORDERED that petitioners' motion to dismiss for lack of prosecution is recharacterized as petitioners' motion for default judgment pursuant to Rule 123(a). It is further
ORDERED that respondent shall respond to the motion for default judgment within the status report due on April 7, 2023.