Opinion
7243-21L
10-19-2022
REVENUE GUARD MEDICAL CLAIMS MANAGEMENT, L.L.C., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge
By order served September 30, 2022, the Court directed petitioner to file a reply to respondent's response to his Motion for Judgment on the Pleadings, and include in the reply petitioner's arguments regarding how Frieje v. Commissioner, 125 T.C. 14 (2005), may apply in this case. On October 11, 2022, petitioner filed a Reply to Respondent's Notice of Objection and Motion to Dismiss on Grounds of Mootness (reply).
Petitioner did not comply with the Court's order because the reply makes arguments outside of the scope of what was directed in the Court's September 30, 2022, order. Therefore, the Court will strike the reply and direct petitioner to file a reply to respondent's response to petitioner's Motion for Judgment on the Pleadings.
Upon due consideration, it is
ORDERED that petitioner's Reply to Respondent's Notice of Objection and Motion to Dismiss on Grounds of Mootness, filed October 11, 2022, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that petitioner shall, no later than November 2, 2022, file a reply to respondent's response to his Motion for Judgment on the Pleadings, and include in the reply petitioner's arguments regarding how Frieje v. Commissioner, 125 T.C. 14 (2005), may apply in this case.