Opinion
16739-19L
02-23-2022
Jacob Rozbruch & Marsha Rozbruch Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
DAVID GUSTAFSON, JUDGE
On February 22, 2022, the parties filed a joint status report proposing a schedule for further activity. To adopt the schedule they have proposed, it is now
ORDERED, as to any motion to dismiss for lack of jurisdiction that respondent intends to file, that
+ on or before February 24, 2022, respondent shall file the motion to dismiss;
+ on or before March 7, 2022, petitioners shall file their response to respondent's motion to dismiss; and
+ on or before March 21, 2022, respondent shall file his reply to petitioners' response to the motion to dismiss. It is further
ORDERED, as to petitioners' motion for summary judgment filed on January 25, 2022, that
+ on or before March 14, 2022, petitioners shall file a supplement to their motion, taking account of respondent's issuance of supplemental notices of determination;
+ on or before April 11, 2022, respondent shall file his response to petitioners' motion, as supplemented; and
+ on or before April 25, 2022, petitioners shall file their reply to respondent's response to petitioner's motion, as supplemented. It is further
ORDERED, as to any cross-motion for summary judgment that respondent intends to file in this case, that
+ on or before April 11, 2022, respondent shall file the cross-motion;
+ on or before May 9, 2022, petitioners shall file their response to respondent's cross-motion; and1
+ on or before May 23, 2022, respondent shall file his reply to petitioners' response to respondent's cross-motion.2