Opinion
35190-21
10-02-2023
DAVID HAZAN & GRACE HAZAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On September 28, 2023, respondent filed in the above-docketed matter 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.
Upon due consideration, it is
ORDERED that, on or before October 27, 2023, petitioners shall file a reply, if any, to the First Amendment to Answer in accordance with Rule 37(a) and (b) of this Court's Rules. The Court advises that respondent's just-referenced motion will be denied if such reply is filed as directed. Conversely, the motion will be granted if such reply is not filed as directed, thereby deeming admitted for purposes of this case the affirmative allegations set forth in the First Amendment to Answer.