Opinion
12525-23
01-11-2024
HANNAH M. HOLLAND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
By Order issued November 21, 2023, the Court directed petitioner to file a Reply to the affirmative allegations contained in paragraph 7 of respondent's Answer, filed September 29, 2023. On January 8, 2024, petitioner filed a Reply to Answer. Paragraph 7 of petitioner's Reply, however, does not conform to the requirements of Rule 37(b), Tax Court Rules of Practice and Procedure, concerning the proper form and content of a Reply to affirmative allegations set forth in an Answer.
Upon due consideration of the foregoing, it is
ORDERED that petitioner's above-referenced Reply to Answer is stricken from the Court's record. It is further
ORDERED that the due date for petitioner to file a Reply to Answer is extended to February 12, 2024. If petitioner does not file a Reply as directed, the Court may grant respondent's above-referenced motion and pursuant to Rule 37(c) deem admitted for purposes of this case the affirmative allegations set forth in paragraph 7 of respondent's Answer.