Opinion
6551-23
12-14-2023
SYRUS PARVIZIAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On October 10, 2023, petitioner filed a First Amended Petition. On November 27, 2023, respondent filed an Answer. Because that document is more akin to an answer to amended petition, we will recharacterize it as set forth below.
On December 11, 2023, petitioner filed a Letter dated December 3, 2023, and a Reply to Answer. However, the document filed as a Reply to Answer does not comply with the requirements set forth for such a pleading in Rule 36(b) of the Tax Court Rules of Practice and Procedure and is therefore not appropriately designated as such. We will accordingly recharacterize it as set forth below.
Additionally, we note that, in both of the aforementioned filings made on December 11, 2023, petitioner incorrectly states that Sharon Y. Tang, counsel for respondent, has not entered an appearance in this case. Petitioner is informed that Ms. Tang entered a proper appearance in this case on November 27, 2023, by signing and filing the Answer. See Rule 24(a)(1)(A), Tax Court Rules of Practice and Procedure.
Upon due consideration and for cause, it is
ORDERED that respondent's Answer is recharacterized as respondent's Answer to Amended Petition. It is further
ORDERED that petitioner's Reply to Answer is recharacterized as petitioner's Status Report.