Opinion
20882-21
11-09-2022
ALAN HAMEL & SUZANNE HAMEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi, Special Trial Judge.
On January 26, 2022, respondent filed in this case a Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c) of the Tax Court Rules of Practice and Procedure. By Order issued October 4, 2022, the Court afforded petitioners an opportunity to file the delinquent reply to respondent's Answer on or before November 1, 2022. The Order advised petitioner that respondent's motion would be granted if such a reply was not filed as directed. Petitioners filed a Reply on November 1, 2022. Accordingly, the premises considered, it is
ORDERED that respondent's Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c), filed January 26, 2022, is denied.