Opinion
9841-21
09-12-2022
CLARENCE SMITH & ATIAH SMITH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
L. Paige Marvel Judge
This case is calendared for trial at the Court's Philadelphia, Pennsylvania, trial session scheduled to begin on October 31, 2022. On September 6, 2022, petitioners filed a motion for summary judgment. The Court will deny petitioners' motion without prejudice because the motion reveals on its face that there is an issue of material fact in dispute. Accordingly, it is
ORDERED that petitioners' motion for summary judgment, filed September 6, 2022, is denied without prejudice.