Opinion
23204-16
02-04-2022
Emilio M. Cerejo & Dawn H. Cerejo Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Christian N. Weiler Judge
This case is calendared for trial at a special trial session commencing June 6, 2022, in Miami, Florida. The issues for decision are whether petitioners are liable for deficiencies and fraud penalties due to their alleged receipt of unreported income for tax years 2003 through 2011. On February 2, 2022 respondent filed an unopposed Motion for Leave to File a Reply to Petitioners' Response to Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) ("Motion for Leave"). At the same time, respondent lodged with the Court a copy of his Reply to Petitioners' Response to Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) (Reply).
Considering the foregoing, it is
ORDERED that respondent's Motion for Leave is granted. It is further
ORDERED that the Clerk of Court is directed to file respondent's Reply into the record of this proceeding as of the date of this order. It is further
ORDERED that a telephone status conference with the Court and the parties herein is set for February 18, 2022, at 11:00a.m. (EST) to discuss the current status of the Stipulation of Facts in this case and respondent's Rule 91(f) motion. The Court will separately furnish counsel for the parties dial-in information for the telephone status conference, and if counsel for the parties are unavailable at this scheduled time, counsel is to notify Chambers as soon as possible.