Opinion
4576-21
06-09-2023
DOUGLAS A. CICHON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Courtney D. Jones Judge.
This case is on the calendar of the Court's September 11, 2023, trial session for Denver, Colorado. On June 20, 2023, respondent filed a Motion to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established Pursuant to Tax Court Rule 91(f) (Doc. 21). Upon due consideration, it is
ORDERED that respondent's Motion to Show Cause is granted. It is further
ORDERED that, on or before June 30, 2023, petitioner shall file a response to this Order showing cause why the facts and evidence set forth in respondent's proposed Stipulation of Facts (attached to respondent's motion as Exhibit B) should not be accepted as established for purposes of this case and in compliance with the provisions of Rule 91(f)(2), with proof of service of a copy on respondent. If no response is filed within the period specified above, with respect to any matter or portion thereof, or if the response is evasive or not fairly direct to the proposed stipulation or portion thereof, that matter or portion will be deemed stipulated for the purpose of the pending case and an order will be entered pursuant to Rule 91(f)(3).