Opinion
24179-22L
06-15-2023
ORDER
Kathleen Kerrigan, Chief Judge
On June 14, 2023, respondent filed a Motion for Summary Judgment, in which respondent asserts that this case can be decided in respondent's favor because there are no genuine issues for trial/no material facts in dispute. Upon due consideration, it is
ORDERED that, on or before July 19, 2023, petitioner shall file a Response, if any, to the above-described 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.