Umoren v. Comm'r of Internal Revenue

Full title: Isang E. Umoren Petitioner v. Commissioner of Internal Revenue Respondent

Court: United States Tax Court

Date published: Mar 24, 2022

No. 10226-21L (U.S.T.C. Mar. 24, 2022)

Opinion

10226-21L

03-24-2022

Isang E. Umoren Petitioner v. Commissioner of Internal Revenue Respondent

Emin Toro Judge

ORDER

Emin Toro Judge

This case is currently calendared for trial during the Court's May 9, 2022, Washington, D.C., trial session. On March 8, 2022, the Court received by mail from petitioner a document entitled "Motion for Summary Judgment." On March 10, 2022, petitioner electronically filed a document entitled "Update Motion for Swift Judgement" (Doc. 19). The cover page of the document is labeled "Motion for Summary Judgment." On March 14, 2022, petitioner electronically filed a document entitled "Motion for Swift Ruling Update Conclusion" (Doc. 22). This document contains a cover page labeled "First Supplement to Motion for Summary Judgment" and a second cover page labeled "Third Amended Motion for Summary Judgment."

By Order served March 14, 2022, respondent was directed to file a response to petitioner's Motion for Summary Judgment on or before April 4, 2022 (Doc. 19).

Upon further review of all the materials received by mail and electronically filed by petitioner on March 8, March 10, and March 14, it appears that the "Motion for Summary Judgment" received by mail on March 8, 2022, is petitioner's Motion for Summary Judgment, the electronically filed "Update Motion for Swift Judgement" (Doc. 19) is petitioner's First Supplement to Motion for Summary Judgment, and the electronically filed "Motion for Swift Ruling Update Conclusion" (Doc. 22), is petitioner's Second Supplement to Motion for Summary Judgment.

Upon due consideration, it is hereby

ORDERED that petitioner's document entitled "Motion for Summary Judgment" received by mail on March 8, 2022, shall be filed as petitioner's Motion for Summary Judgment. It is further

ORDERED that petitioner's document entitled "Update Motion for Swift Judgement" (Doc. 19) is recharacterized as petitioner's First Supplement to Motion for Summary Judgment. It is further

ORDERED that petitioner's document entitled "Motion for Swift Ruling Update Conclusion" (Doc. 22) is recharacterized as petitioner's Second Supplement to Motion for Summary Judgment. It is further

ORDERED that, on or before April 4, 2022, respondent shall file a response to petitioner's Motion for Summary Judgment as supplemented.