Opinion
22732-19
11-17-2023
JAMES P. CARNEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
Currently pending before the Court is a motion for summary judgment filed by petitioner James P. Carney on October 18, 2023. The Court subsequently issued an Order directing the Commissioner to file a response by November 20, 2023 and directing Mr. Carney to file a reply to the response by December 5, 2023.
On November 15, 2023, the Commissioner filed a motion for extension of time asking the Court to extend the deadline for the Commissioner to file a response to Mr. Carney's motion for summary judgment from November 20, 2023, to a date that is 14 days after the resolution of the Commissioner's motion for protective order pursuant to Rule 103. We will grant this motion for extension of time and also provide an additional time for Mr. Carney's reply. Accordingly, it is
Contemporaneous with this motion, the Commissioner filed a motion for protective order, which seeks an order preventing Mr. Carney's use of summary judgment. We ruled on the motion for protective order and thus, the deadline for the Commissioner to file a response has been extended from the date we served the Order.
ORDERED that the Commissioner's motion for extension of time is granted and that the time in which the Commissioner's response to the motion for summary judgment is extended to December 1, 2023. It is further
ORDERED that the time in which Mr. Carney shall file his reply to the Commissioner's response to the motion for summary judgment is extended to December 18, 2023.