Opinion
2531-24
07-01-2024
JM ASSETS, LP, A-A-A STORAGE, LLC, PARTNERSHIP REPRESENTATIVE, Petitioner(s) v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 28, 2024, respondent filed a Motion to Change or Correct Docket Entry, requesting that an exhibit attached to that Motion be substituted for the Exhibit A currently attached to his Motion for Partial Summary Judgment, filed June 18, 2024. However, such substitution cannot be performed in DAWSON, the Court's current case management system. Therefore, we will recharacterize respondent's Motion to Change or Correct Docket Entry.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Change or Correct Docket Entry is denied. It is further
ORDERED that, on the Court's own motion, respondent's Motion to Change or Correct Docket Entry is recharacterized as respondent's First Supplement to Motion for Partial Summary Judgment. It is further
ORDERED that the time for petitioner to file a response to respondent's Motion for Partial Summary Judgment, as supplemented, is extended to July 29, 2024. Failure to file a response as directed may result in the granting of that Motion. See Rule 121(b), (d), Tax Court Rules of Practice and Procedure.