Opinion
12822-23L
03-29-2024
JOHN B. GIBBONS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge.
Pending before the Court is respondent's Motion for Summary Judgment, filed February 14, 2024.
Tax Court Rule 93 explains that the parties must file with the Court the entire administrative record (or so much of that record as either party may deem necessary for a complete disposition of the issue or issues in dispute) stipulated as to its genuineness.
If, however, the parties are unable to file a stipulated administrative record, the Commissioner must file with the Court the entire administrative record, appropriately certified as to its genuineness by the Commissioner or by an official authorized to act for the Commissioner in such situation. The administrative record has not yet been filed in this case. Upon due consideration, it is
ORDERED that, pursuant to Rule 93, Tax Court Rules of Practice and Procedure, the parties shall file with the Court, on or before April 26, 2024, the entire administrative record (or so much of that record as either party may deem necessary for a complete disposition of the issue(s) in dispute), stipulated to its genuineness. If the parties are unable to file a stipulated administrative record, respondent must file the entire administrative record appropriately certified by the Commissioner or by an official authorized to act for the Commissioner.