Opinion
16874-21 12155-22
06-05-2023
CONTEMPORARY FINE ARTS INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
These cases are currently calendared on the Court's San Diego, California trial session, scheduled to begin June 20, 2023.
On May 8, 2023, the Commissioner filed a motion for order to show cause why proposed facts and evidence should not be accepted as established pursuant to Rule 91(f). The Court thereafter granted the Commissioner's motion and ordered petitioner to show cause why the matters set forth in the Commissioner's proposed stipulation of facts should not be deemed admitted for purposes of these cases. To date, there has been no response by petitioner.
Upon due consideration, it is
ORDERED that the Court's Order to Show Cause served on May 10, 2023, is made absolute, and the facts and evidence set forth in the Commissioner's proposed stipulation of facts, marked as Exhibit A attached to the motion for order to show cause why proposed facts and evidence should not be accepted as established pursuant to Rule 91(f), are deemed to be established for purposes of these cases.