Opinion
16410-18L
01-28-2022
Sabrina N. Sloan & Alfred W. Sloan Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
David Gustafson Judge
On January 27, 2022, the Commissioner filed a motion for summary judgment. The record in this case indicates that petitioner-husband is an attorney, so we assume that he understands the nature of such a motion and the non-movant's obligations under Rule 121 (i.e., the Tax Court's equivalent to Rule 56 of the Federal Rules of Civil Procedure). However, if it would be helpful to receive a refresher, petitioners may consult the Q&As on the subject that appear on the Tax Court's website at: https://ustaxcourt.gov/petitioners_start.html#START39
It is
ORDERED that, no later than February 18, 2022, petitioners shall file a response to the motion. It is further
ORDERED that, no later than March 4, 2022, the Commissioner shall file a reply (or, if petitioners have filed no response, then a status report).