Opinion
3309-21
10-25-2022
ALBERT D. SPORTIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On July 7, 2021, respondent filed a Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c). By Order issued August 18, 2021, the Court directed petitioner to file a reply to the affirmative allegations in respondent's answer. After being granted a number of extensions, on December 29, 2021, petitioner filed a document titled Response to Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c).
In view of the foregoing, it is
ORDERED that petitioner's above-referenced Response to Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c) is recharacterized as a Reply to Answer. It is further
ORDERED that respondent's above-referenced Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c) is denied.
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