Opinion
27150-21S
04-06-2023
DAVID BYRON FUGLER & CINDY DIANE FUGLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On April 3, 2023, petitioners filed in the above-docketed matter a Motion for Leave To File Second Amended Petition . The proposed Second Amended Petition, however, was not lodged simultaneously therewith in accordance with the Tax Court Rules of Practice and Procedure. Rather, the proposed Second Amended Petition was attached to the filed motion.
Accordingly, the premises considered, it is
ORDERED that the Clerk of Court is directed to detach a copy of the proposed Second Amended Petition from the motion for leave and to lodge such document as of the April 3, 2023, date received.
ORDERED that, on or before April 27, 2023, respondent shall file an objection, if any, to petitioners' just-referenced motion for leave.