Opinion
4514-21SL
04-28-2023
MARK P. HAFNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge.
On February 22, 2023, during the Court's Mobile, Alabama trial session, a trial in this matter was held. At the conclusion of the trial, and based on the agreement of the parties, no briefing was ordered in this case, and a stipulation of facts was due by March 24, 2023. On April 10, 2023, however, petitioner lodged a post-trial brief in this matter. On April 20, 2023, a conference with the parties was held, whereby it was discussed whether briefing in this case was needed. During the conference, petitioner orally moved for leave to file his brief; petitioner's oral motion was not opposed by respondent.
Considering the foregoing, it is
ORDERED that on the Court's own motion, petitioner's post-trial brief dated April 10, 2023, shall be filed as petitioner's seriatim opening brief as of the date of this Order and the Clerk of the Court shall serve a copy of petitioner's seriatim opening brief on respondent. It is further
ORDERED that on or before June 30, 2023, respondent shall file his seriatim answering brief. It is further
ORDERED that the record shall remain open until May 30, 2023, for the parties to file a stipulation of facts in this case. It is further
ORDERED that on or before July 31, 2023, petitioner may file a seriatim reply brief to respondent's to-be filed seriatim answering brief.