Opinion
1934-20
03-09-2022
JOHN R. MORAN & CAROLYN P. MORAN, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Tamara W. Ashford, Judge
On March 2, 2022, petitioners filed a Response to Respondent's Motion for Partial Summary Judgment. In the response, petitioners assert that they made an oral claim for refund during the audit of their Federal income tax return for the 2014 taxable year, but this seemingly contradicts respondent's assertion in his motion that "the parties agree that the notice of deficiency (served as the claim) was issued within the period for assessment, as extended". Upon due consideration, it is hereby
ORDERED that respondent shall, on or before March 22, 2022, file with the Court and serve on petitioners a reply to petitioners' Response to Respondent's Motion for Partial Summary Judgment, addressing, in particular, petitioners' assertion that they made an oral claim for refund.