Opinion
27922-21
05-22-2023
JING ZHANG & ZIQI CHEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mary Ann Cohen, Judge.
On December 2, 2022, respondent filed a Motion for Leave to File an Amendment to Answer and lodged the accompanying Amendment to Answer. On March 21, 2023, petitioners filed an Objection to Motion for Leave to File First Amendment to Answer.
Upon due consideration, it is hereby
ORDERED that, on or before June 9, 2023, respondent shall reply to petitioners' Objection insofar as it asks the Court to determine that respondent will bear the burden of proof if the Motion to Amend the Answer is granted. In such reply, respondent shall explain how the burden of proof will be satisfied if the Court determines that respondent bears the burden of proof.