Opinion
25258-21
03-08-2023
RICHARD GOODMAN & AMY GOODMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson Judge
This case is scheduled for trial on May 11, 2023. (See Doc. 19.) However, on March 8, 2023, the Commissioner filed a motion for summary judgment (Doc. 20). It is
ORDERED that, no later than March 31, 2023, petitioners shall file a response to the motion for summary judgment (and, if they intend to cross-move for summary judgment, shall file their cross-motion by that date). It is further
ORDERED that, no later than April 14, 2023, the Commissioner shall file a reply, unless petitioners cross-move, in which event the Commissioner may file either (1) a reply and response or (2) a motion proposing a schedule (preferably with petitioners' concurrence) for the briefing of the cross-motions and proposing any continuance that is deemed necessary in view of the approaching trial date.