Opinion
8132-23
11-14-2023
JASON PAGANESSI & JENNIFER PAGANESSI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On August 18, 2023, respondent files a Motion for Leave to File Out of Time Answer and lodged therewith an Answer. On October 17, 2023, petitioners filed an Opposition to Motion for Leave to File Out of Time Answer and Motion to Award Abatement of Underpayment Penalty and Interest, a supplement to the motion, and four memoranda in support of the supplement. Because petitioners' opposition and motion, as supplemented, constitutes an impermissible joinder of motions, the Court will strike those filings from the record. See Rule 54(b), Tax Court Rules of Practice and Procedure.
Upon due consideration, it is
ORDERED that petitioners' Opposition to Motion for Leave to File Out of Time Answer and Motion to Award Abatement of Underpayment Penalty and Interest, as supplemented, and four Memoranda, filed October 17, 2023, are deemed stricken from the Court's record.