Opinion
27494-16 21889-21
12-19-2023
GARY C. GEORGE & ROBIN A. GEORGE, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Travis A. Greaves Judge
On December 6, 2023, petitioners filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f). Petitioners appended to the Motion a proposed Stipulation of Facts. Petitioners request that the Court order respondent to show cause why the facts and evidence set forth in petitioners' proposed Stipulation, marked "Exhibits A and C," should not be deemed established for the purposes of these cases.
Upon due consideration, it is
ORDERED that petitioners' Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) is granted. It is further
ORDERED that respondent shall file with the Court, on or before January 12, 2024, a response in compliance with the provisions of Tax Court Rule 91(f), with proof of service of a copy thereof on petitioners' counsel, showing why the facts and evidence set forth in petitioners' Stipulation should not be deemed accepted as established for purposes of these cases. If no response is filed within the period specified above with respect to any matter or portion thereof, or if the response is evasive or not fairly directed to the proposed Stipulation or a portion thereof, that matter or portion thereof will be deemed stipulated for the purpose of the pending case, and an order will be entered accordingly pursuant to Tax Court Rule 91(f).