Opinion
14564-22P
01-27-2023
JAMES R. RAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge
This passport case is calendared for trial at the Court's March 27, 2023, St. Paul, Minnesota trial session. On January 26, 2023, the Commissioner filed a Motion for Summary Judgment. According to the Commissioner, a trial is not necessary in this case because no relevant facts are in dispute. Based on the facts stated by the Commissioner, the Commissioner claims that the law requires the Court to decide this case in his favor. We will provide Mr. Ray the opportunity to file a written response to the Commissioner's motion. If he agrees with the Commissioner, he can let us know in his response. If he disagrees with the facts in the Commissioner's motion, then his response should tell us the specific facts with which he disagrees. If he disagrees with the Commissioner's legal arguments, then his response should include his legal arguments. More information can be found at https://ustaxcourt.gov/petitioners_start.html#START39.
Under Tax Court Rule 121(d) and Internal Revenue Code section 7459(d), if Mr. Ray does not respond to this Order, then the Court can enter a decision against him ending this case in the Commissioner's favor.
In accordance with the foregoing, it is
ORDERED that, by February 24, 2023, Mr. Ray shall file with the Court a response to the Commissioner's Motion for Summary Judgment.