Opinion
13400-18
10-14-2021
Leigh C. Fairbank & Barbara J. Fairbank Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Christian N. Weiler Judge
This case is calendared for trial at a Date and Time Certain of December 16, 2021, during the remote session of the Court where Jacksonville, Florida is the place of trial for administrative purposes. On October 13, 2021, respondent filed a motion for summary judgment in respondent's favor in this case upon the issue of whether respondent complied with the requirements of I.R.C. section 6751(b)(1) as they apply to the penalties at issue in this case under I.R.C. section 6662(a), (b)(1), (c).
Upon due consideration, it is
ORDERED that, on or before November 5, 2021, petitioners shall file with the Court and serve on respondent's counsel, a response to the motion for summary judgment.
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