Opinion
3237-22S
10-18-2022
FRANK R. MCNAMARA & COLLETTE M. MCNAMARA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi, Special Trial Judge.
On October 11, 2022, the parties filed a joint Motion to Submit Case Pursuant to Rule 122. In their Motion, the parties requested that the case be submitted without trial and decided solely on the basis of the pleadings and the facts recited in the Stipulation of Facts, filed on October 11, 2022. On October 14, 2022, this Court granted the parties' joint Motion to Submit Case Pursuant to Rule 122.
Upon due consideration, it is hereby
ORDERED that on or before December 6, 2022, the parties shall file with the Court simultaneous Opening Briefs, not to exceed 15 pages. It is further
ORDERED that on or before January 20, 2023, the parties shall file simultaneous answering briefs, not to exceed 15 pages.
See Rule 151(e) of the Tax Court Rules of Practice and Procedure for the form and content of the briefs.