Opinion
3852-21
02-22-2023
BM CONSULTANT, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.
ORDER
Tamara W. Ashford Judge
This case is currently calendared for a remote proceeding on February 27, 2023. On January 13, 2023, respondent filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f). By Order to Show Cause served on the parties on January 18, 2023, the Court granted respondent's motion and ordered petitioner to file a response on or before February 7, 2023, in compliance with the provisions of Tax Court Rule 91(f)(2), or agree upon a Stipulation of Facts and file it with the Court prior to February 7, 2023. As of the date of this Order, petitioner has not responded to either respondent's motion or the Court's January 18, 2023, Order to Show Cause. Upon due consideration, it is hereby
ORDERED that the Court's Order to Show Cause under Rule 91(f), served on the parties on January 18, 2023, is made absolute, and the facts and evidence set forth in respondent's proposed Stipulation of Facts, marked as Exhibit A, are deemed to be established for purposes of this case.