Opinion
20894-19 6791-20 10830-20 17749-21 17771-21
06-23-2023
NOEL M. PARDUCCI & KENNETH L. PARDUCCI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge.
On June 16, 2023, Mr. Simpson filed a Motion to Compel Stipulation and Admissions from Petitioner Hoyal, at docket entry 149, in docket number 17771-21, and a Motion to Compel Stipulation and Admissions from Respondent, at docket entry 150, in docket number 17771-21. These motions should be recharacterized as motions for order to show cause. Although this is a group of consolidated cases, the parties to each of the cases are different and they currently cannot electronically file these documents in all of the consolidated cases. Accordingly, it is
ORDERED that the Motion to Compel Stipulation and Admissions from Petitioner Hoyal, at docket entry 149, in docket number 17771-21, shall be recharacterized as a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) from Petitioner Hoyal. It is further
ORDERED that the Motion to Compel Stipulation and Admissions from Respondent, at docket entry 150, in docket number 17771-21, shall be recharacterized as a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) from Respondent. It is further
ORDERED that the Clerk of the Court shall file docket entry 149, as recharacterized, filed in Docket No. 17771-21 in the consolidated cases at 20894-19, 6791-20, 10830-20, and 17749-21 as of June 16, 2023. It is further
ORDERED that the Clerk of the Court shall file docket entry 150, as recharacterized, filed in Docket No. 17771-21 in the consolidated cases at 20894-19, 6791-20, 10830-20, and 17749-21 as of June 16, 2023.