Opinion
12024-18
09-24-2021
The Harbinder S Brar FLP II n.k.a. Bosh LP, Brar Property Management Inc., Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On September 9, 2021, respondent filed a motion for summary judgment, wherein respondent asserts that there is no genuine dispute as to any material fact and that a decision may be rendered in respondent's favor as a matter of law. In support of his motion, respondent concurrently filed three declarations and a memorandum. Respondent states that petitioner objects to the granting of the motion.
The Court will order petitioner to file a response, if any, to respondent's motion. In the response, petitioner should point out the specific facts in dispute if petitioner disagrees with the facts set forth in respondent's motion, and petitioner should state petitioner's position on the disputed legal issues if petitioner disagrees with respondent's arguments as to the law.
Upon due consideration, it is
ORDERED that, on or before October 25, 2021, petitioner shall file a response, if any, to the above-referenced motion for summary judgment. Failure to comply with this Order may result in the granting of respondent's motion for summary judgment, and a decision, if appropriate, may be entered against petitioner. See Rule 121(b), Tax Court Rules of Practice and Procedure.
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