Gammel v. Comm'r of Internal Revenue

Full title: Jamie Michelle Gammel & Celeste Colleen Gammel Petitioners v. Commissioner…

Court: United States Tax Court

Date published: Jan 25, 2022

No. 6634-20 (U.S.T.C. Jan. 25, 2022)

Opinion

6634-20

01-25-2022

Jamie Michelle Gammel & Celeste Colleen Gammel Petitioners v. Commissioner of Internal Revenue Respondent

Alina I. Marshall Judge

ORDER

Alina I. Marshall Judge

On November 24, 2021, at 1:51 a.m., petitioners filed a document titled "Response to Response to Motion to Dismiss". On the same day, at 1:53 a.m., petitioners filed a document titled "Response to Response to Motion to Dismiss". Additionally, on November 24, 2021, at 1:53 a.m., petitioners filed a document titled "Brief in Support of Response to Response to Motion to Dismiss". After review of petitioners' filings, the Court concludes that petitioners' documents are in fact a response to respondent's motion to dismiss for lack of prosecution filed September 13, 2021. Accordingly, the Court will recharacterized petitioners' filings appropriately.

Upon due consideration of the foregoing, it is

ORDERED that petitioners' document titled "Response to Response to Motion to Dismiss" filed November 24, 2021, at 1:51 a.m., is recharacterized as petitioners' response to respondent's motion to dismiss for lack of prosecution. It is further

ORDERED that petitioners' document titled "Response to Response to Motion to Dismiss" filed November 24, 2021, at 1:53 a.m., is recharacterized as petitioners' brief in support of response to respondent's motion to dismiss for lack of prosecution. It is further

ORDERED that petitioners' document titled "Brief in Support of Response to Response to Motion to Dismiss" filed November 24, 2021, at 1:53 a.m., is recharacterized as petitioners' brief in support of response to respondent's motion to dismiss for lack of prosecution.