Opinion
20882-21
10-02-2023
ALAN HAMEL & SUZANNE HAMEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge
On September 22, 2023, respondent filed a Motion for Summary Judgment, pursuant to Rule 121, and a Memorandum in support thereof. The motion seeks summary judgment in respondent's favor upon all issues in controversy, except for the penalties-an issue which respondent contends in its August 08, 2023, Motion to Dismiss for Lack of Jurisdiction that this Court does not have jurisdiction over. The Motion for Summary Judgment also advises the Court that petitioners object to the granting of the motion.
Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure.
On September 22, 2023, petitioners also filed a Motion for Summary Judgment, pursuant to Rule 121. Petitioners also filed a Statement of Undisputed Facts, Declaration of Clifton Lamb, and Memorandum all in support of their Motion for Summary Judgment. The motion seeks summary judgment in petitioners' favor upon all issues in controversy. The motion also advises the Court that respondent objects to the granting of the motion.
To resolve both respondent's and petitioners' Motions for Summary Judgment, it is
ORDERED that petitioners shall file a response, on or before October 27, 2023, to respondent's Motion for Summary Judgment. It is further
ORDERED that respondent shall file a response, on or before October 27, 2023, to petitioners' Motion for Summary Judgment.