Opinion
6614-24
08-21-2024
CHARLES E. SULLO & SUSIE G. SULLO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE
Upon due consideration of respondent's Motion for Entry of Order That Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c), filed August 16, 2024, it is
ORDERED that, on or before October 7, 2024, petitioners shall file a reply to the affirmative allegations set out in paragraph 7 (including the subparagraphs) of respondent's Answer, filed May 22, 2024. In accordance with Rule 37(b) of the Tax Court Rules of Practice and Procedure, any such reply shall contain a specific admission, denial, or claim of lack of information with respect to each of the affirmative allegations. Failure to file such a reply may result in the granting of respondent's above-referenced Motion and the deemed admission of the affirmative allegations for purposes of this case.