Opinion
12120-20L
02-03-2022
Winthrop G. Gardner & Laurie K. Gardner Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
David Gustafson, Judge
Our order of January 11, 2022 (Doc. 9), required petitioners to file a response to the Commissioner's motion for summary judgment (Doc. 6) no later than January 21, 2022, and required the Commissioner to file a reply (or, if no response had been filed, a status report) no later than February 4, 2022.
On February 1, 2022, the Commissioner filed a status report. The document as filed (Doc. 10) includes both the Commissioner's reply and (as "Exhibit A" to that reply) petitioners' memorandum in opposition to motion for summary judgment. For the clarity of our record, it is
ORDERED that the Clerk of the Court shall make a copy of the Commissioner's status report, filed February 1, 2022 (Doc. 10), and shall file, as of that date, Exhibit A therefrom (i.e., the pages numbered 7 through 15 in the "PDF" digital file) as petitioners' memorandum in opposition to motion for summary judgment. It is further
ORDERED that the Clerk of the Court shall recharacterize the Commissioner's status report (Doc. 10) as respondent's reply to petitioners' opposition to motion for summary judgment.