Opinion
17958-21
12-21-2021
Marcelo A. Polimeni Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On December 16, 2021, respondent filed in the above-docketed matter 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 January 14, 2022, petitioner shall file a reply, if any, to the answer in accordance with Rule 37(a) and (b) of this Court's Rules. 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.
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