Opinion
23204-16
02-16-2022
Emilio M. Cerejo & Dawn H. Cerejo Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Christian N. Weiler Judge
On February 15, 2022, 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) of the Court's Rules of Practice and Procedure. Pursuant to the provisions of that Rule, it is
ORDERED that respondent's above-referenced motion is granted. It is further
ORDERED that, on or before March 18, 2022, petitioners shall file with the Court a response in compliance with the provisions of Rule 91(f)(2), with proof of service of a copy thereof on respondent's counsel, showing cause why the matters set forth in respondent's proposed second stipulation of facts, including the corresponding proposed Exhibit 5-R through 8-R in respondent's motion, should not be deemed admitted for purposes of this pending case. If petitioners fail to file a response within the period specified above with respect to any matter or portion thereof, or if petitioners' response is evasive or not fairly directed to the proposed second stipulation or portion thereof, then that matter or portion thereof, may be deemed stipulated for purposes of this pending case, and an Order may be entered accordingly, pursuant to Rule 91(f)(3) of the Tax Court Rules of Practice and Procedure.