Opinion
16247-23L
05-02-2024
WANRIETTA FAYE COURSEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch, Judge
This case is calendared for trial at the session of the Court commencing on September 30, 2024, in Indianapolis, Indiana. On May 1, 2024, Commissioner filed a Motion for Summary Judgment in which Commissioner asserts that there is no genuine issue of material fact in dispute and that this case can be decided in Commissioner's favor as a matter of law.
If petitioner disagrees with the facts set forth in Commissioner's Motion for Summary Judgment, then any such response should point out the specific facts in dispute and explain why those facts are in dispute. If petitioner disagrees with Commissioner's argument as to the law, then any such response should also set forth petitioner's position on the disputed legal issues. The Court has prepared questions and answers on the subject "What is a motion for summary judgment? How should I respond to one?" which can be found on the Court's website (specifically, https://www.ustaxcourt.gov/petitioners_start.html#START40). Petitioner should note that failing to respond to the Commissioner's motion (and this Order) may result in a decision being entered for the Commissioner. See Rule 121(d), Tax Court Rules of Practice and Procedure. To provide petitioner the opportunity to respond to the Commissioner's Motion, it is
ORDERED that, by May 24, 2024, petitioner shall file a response to Commissioner's Motion for Summary Judgment.