USTC Rule 213 Reply to Answer

Group:

It's been a while since I filed a Declaratory action for retirement plan disqualification filed in USTC. 

In the Reply to Govt Answer am I correct the only paragraphs I should reply to relate to where the Govt has burden of proof.  Under USTC rule 213 says:

Rule 213 Form and Content:   "In response to each material allegation in the answer and the facts in support thereof on which the Commissioner has the burden of proof, the reply must contain a specific admission or denial; however, if the petitioner lacks knowledge or information sufficient to form a belief as to the truth of an allegation, the petitioner must so state, and that statement will have the effect of a denial. "

I've always thought that unless there's a new issue under US tax court rule 142 the burden almost always stays with petitioner. Or of course if the court shifts burden under 7491. Which seems to be very rare. 

Thoughts on how do you prepare your Reply? 

Do you Reply to each Answered paragraph? 

Thoughts and comments appreciated.