Opinion
24344-17 11352-18 25268-18
03-22-2022
SUNIL S. PATEL & LAURIE MCANALLY PATEL, ET. AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND ORDER TO SHOW CAUSE
Courtney D. Jones Judge
This consolidated case is scheduled for trial at a special session of the Court, to commence on April 25, 2022 at 10:00 a.m., in the South Courtroom, 400 Second Street NW, Washington, D.C. 20217. On February 24, 2022, respondent filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established under Rule 91(f) of this Court's Rules of Practice and Procedure. On March 4, petitioners filed an opposition to respondent's motion.
Giving due regard to the representations contained in respondent's above-referenced motion, and in accordance with the procedures set forth in Rule 91(f) of this Court's Rules, it is
ORDERED that respondent's motion is granted. It is further
ORDERED that petitioners show cause at the above-listed time, date, and place why the matters covered in respondent's motion for order to show cause, should not be deemed admitted for purposes of this case.