Opinion
17490-23
04-04-2024
TYZ PROPERTIES, LLC, TYZ MANAGER, LLC, PARTNERSHIP REPRESENTATIVE, Petitioner(s) v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On March 11, 2024, respondent filed in the above-docketed matter a Motion for Entry of Order that Undenied Allegations Be Deemed Admitted Pursuant to Rule 37(c) of the Tax Court Rules of Practice and Procedure. By Order issued March 13, 2024, the Court afforded petitioner an opportunity to file the delinquent reply to respondent's answer on or before April 3, 2024. The Order advised petitioner that respondent's motion would be denied if such reply as required by Rule 37(a) and (b) was filed and that the motion would be granted if such reply was not filed as directed. Petitioner so filed a reply on April 3, 2024. Accordingly, the premises considered, it is
ORDERED that respondent's just-referenced March 11, 2024, motion is denied.