Opinion
13263-22
08-29-2022
SEYON EBRAHIMPOUR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 25, 2022, 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. Although petitioner on August 26, 2022, filed a document that could potentially be intended as a reply, such submission did not conform with Rule 37(a) and (b) and hence was not in the nature of a reply. Rather, it appeared to be more analogous to a response to respondent's Motion.
Accordingly, by Order served August 29, 2022, the Court directed petitioner to file a proper reply that admits or denies the specific allegations in the answer. Additionally, to prevent confusion in the record, it is
ORDERED that the document filed August 26, 2022, by petitioner shall be recharacterized as a Response to Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c). The Court reminds petitioner that a proper reply is due on or before September 23, 2022.