Opinion
4986-21
07-11-2023
GAIL A. SYLVESTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall Judge.
On July 5, 2023, respondent filed a Motion for Leave to File Notice of Filing of the Administrative Record. This motion was made pursuant to Rule 93(a), Tax Court Rules of Practice and Procedure which states, in pertinent part, that the parties must file with the Court no later than 45 days after the notice setting the case for trial is served, the entire administrative record (or so much of that record as either party may deem necessary for a complete disposition of the issue or issues in dispute) stipulated as to its genuineness.
Pursuant to Rule 93(a), the due date for filing the stipulated administrative record is July 7, 2023. Respondent's motion appears to be more appropriately characterized as a motion for extension of time to file. Premises considered, it is
ORDERED that respondent's Motion for Leave to File Notice of Filing of the Administrative Record, filed July 5, 2023, is hereby recharacterized as respondent's Motion for Extension of Time to File the Stipulated Administrative Record. It is further
ORDERED that respondent's Motion for Extension of Time to File the Stipulated Administrative Record, filed July 5, 2023, is granted and the time within which the parties shall file the administrative record in this case is extended to August 7, 2023.