Opinion
28898-10 5819-11 5821-11 6034-11
08-13-2024
HERBERT HIRSCH & BONITA HIRSCH, ET AL Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge.
On July 18, 2024, petitioners Herbert Hirsch and Bonita Hirsch filed a motion for partial summary judgment requesting that the Court hold 26 C.F.R. sections 1.162-1, 1.162-7, and 1.162-8 invalid and void under the Administrative Procedure Act. The Court issued an Order on July 30, 2024 directing the Commissioner to file a response by August 12, 2024, and the Hirsches to file a reply by September 3, 2024.
On August 8, 2024, the Commissioner filed an unopposed motion for extension of time to September 11, 2024 to file a response to the motion for partial summary judgment referenced above.
Upon due consideration, it is
ORDERED that the Commissioner's motion for extension of time to September 11, 2024, is granted, and the time in which the Commissioner shall file his response to the motion for partial summary judgment referenced above is extended until September 11, 2024. It is further
ORDERED that the time in which the Hirsches shall file a reply to the Commissioner's response to the motion for partial summary judgment is due October 2, 2024.