Opinion
7896-19
02-04-2022
CASSANDRA TUCKER & EDWARD BRODIE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
TAMARA W. ASHFORD, JUDGE
By Order served on the parties on December 17, 2021, the Court in pertinent part granted respondent's December 16, 2021, Motion for Leave to File Seriatim Opening Brief Out of Size and directed the Clerk of the Court to file respondent's Seriatim Opening Brief, which respondent lodged December 16, 2021. Respondent' Seriatim Opening brief was filed on December 17, 2021.
On January 27, 2022, 41 days after the Court's December 17, 2021, Order, petitioner Cassandra Tucker filed a Motion for Reconsideration of the Court's December 17, 2021 Order Granting Respondent's Motion for Leave to File Seriatim Opening Brief Out of Size, along with a Declaration of Cassandra Tucker in Support of Motion for Reconsideration of the Court's December 17, 2021 Order Granting Respondent's Motion for Leave to File Seriatim Opening Brief Out of Size. Additionally, on the same day, Ms. Tucker filed a duplicate Motion for Reconsideration of the Court's December 17, 2021 Order Granting Respondent's Motion for Leave to File Seriatim Opening Brief Out of Size.
On January 28, 2022, Ms. Tucker filed a Seriatim Answering Brief, along with a Declaration of Cassandra Tucker in Support of Seriatim Answering Brief. The supporting document is a Form 1098, Mortgage Interest Statement, for the 2013 taxable year. This document is in the nature of evidence (not pertaining to the taxable years at issue), and the evidentiary record is closed in this case. Upon due consideration, it is hereby
ORDERED that petitioner's Motion for Reconsideration of the Court's December 17, 2021 Order Granting Respondent's Motion for Leave to File Seriatim Opening Brief Out of Size, filed January 27, 2022, which is referenced as docket entry number 47, is denied. It is further
ORDERED that petitioner's duplicate Motion for Reconsideration of the Court's December 17, 2021 Order Granting Respondent's Motion for Leave to File Seriatim Opening Brief Out of Size, filed January 27, 2022, which is referenced as docket entry number 49, is stricken from the Court's record in this case. It is further
ORDERED that petitioner's Declaration of Cassandra Tucker in Support of Seriatim Answering Brief, filed January 28, 2022, is stricken from the Court's record in this case.