Opinion
6709-19L
04-21-2022
ROBERT L. STEPHENSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson, Judge
The Commissioner filed a motion (Doc. 19) for summary judgment; petitioner Robert L. Stephenson filed a response (Doc. 27); and the Commissioner filed a reply (Doc. 29). By our order of January 26, 2022 (Doc. 30), we directed Mr. Stephenson to file a supplemental response, and we indicated four subjects that we perceived he should address in that supplemental response. After an extension (see Doc. 32), he filed a document entitled "Motion to Deny Summary Judgement and to Grant the Relief Sought in this Pleadings" (Doc. 33), which we understand to be his supplemental response intended to be in compliance with our order. It is
ORDERED that the Clerk of the Court shall recharacterize Doc. 33 as "Petitioner's Supplemental Response to Respondent's Motion for Summary Judgment". It is further
ORDERED that, no later than May 13, 2022, the Commissioner shall file a reply to the supplemental response, which reply shall include a discussion of the four subjects in our order (Doc. 30).