Opinion
16812-18
11-10-2022
PAUL C. ROBINSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones, Judge
This case is calendared for trial at the remote session of the Court scheduled to commence on December 12, 2022, for Baltimore, Maryland.
On November 7, 2022, petitioner filed a Motion for Summary Judgment. We will deny Mr. Robinson's motion as untimely. Rule 121(a), Tax Court Rules of Practice & Procedure, requires that any motion for summary judgment be filed "no later than 60 days before the first day of the Court's session at which the case is calendared for trial, unless otherwise permitted by the Court." Mr. Robinson did not file his motion within the time prescribed by the Court's Rule. Nor did he request leave to file the motion out of time. At this late date, acting on Mr. Robinson's motion would only delay resolution of this case.
Accordingly, it is
ORDERED that petitioner's Motion for Summary Judgment, filed November 7, 2022, is denied.