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Langer v. Comm'r of Internal Revenue

United States Tax Court
Aug 17, 2022
No. 7375-22 (U.S.T.C. Aug. 17, 2022)

Opinion

7375-22

08-17-2022

HENRY J. LANGER & PATRICIA K. LANGER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan, Chief Judge.

On August 15, 2022, respondent filed a Motion for Entry of Order That Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c), requesting that the affirmative allegations set forth in paragraph 9 of the answer, including subparts, filed May 17, 2022, be deemed admitted. When, as here, respondent in his answer has made affirmative allegations on which respondent has the burden of proof, Rule 37(a) and (b), Tax Court Rules of Practice and Procedure, provides that petitioners shall have the opportunity to file a Reply.

Upon due consideration of the foregoing, it is

ORDERED that, on or before September 29, 2022, petitioners shall file a Reply to the affirmative allegations in paragraph 9 of respondent's answer, including subparts, pursuant to Rule 37(a) and (b), Tax Court Rules of Practice and Procedures. If petitioners do not file a reply as directed herein, the Court will 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 respondent's answer.


Summaries of

Langer v. Comm'r of Internal Revenue

United States Tax Court
Aug 17, 2022
No. 7375-22 (U.S.T.C. Aug. 17, 2022)
Case details for

Langer v. Comm'r of Internal Revenue

Case Details

Full title:HENRY J. LANGER & PATRICIA K. LANGER, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Aug 17, 2022

Citations

No. 7375-22 (U.S.T.C. Aug. 17, 2022)