Opinion
15619-21
08-05-2024
MICHAEL FEA & TANYA FEA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
James S. Halpern Judge.
On July 24, 2024, respondent filed a Motion for Partial Summary Judgment (Motion). On August 2, 2024, petitioners filed a Response to the Motion (Response) along with affidavits in support, in which Response petitioners respond to the Motion and cross move for summary judgment. Because the Response constitutes an impermissible joinder of motions, the Court will strike that filing from the record. See Rule 54(b), Tax Court Rules of Practice and Procedure. Upon due consideration, it is
ORDERED that the Response (docket entry 21), and affidavits in support (docket entries 22 and 23) are deemed stricken from the Court's record and shall not be viewable as part of this case. It is further
ORDERED that the time within which petitioners shall file an objection, if any, to the Motion is extended to August 12, 2024. Failure to comply with this Order may result in the granting of the Motion and dismissal of this case or other appropriate action by this Court.