Opinion
6338-23
09-28-2023
ANTONIO GOULART & CECILIA PEISHOT-PEREZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 22, 2023, respondent filed a Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c) of the Tax Court Rules of Practice and Procedure.
Upon due consideration, it is
ORDERED that, on or before October 17, 2023, petitioners shall file a reply, if any, to the answer in accordance with Rule 37(a) and (b), Tax Court Rules of Practice and Procedure. The Court advises that respondent's just-referenced motion will be denied if such reply is filed as directed. Conversely, the motion will be granted if such reply is not filed as directed, thereby deeming admitted for purposes of this case the affirmative allegations set forth in the answer.