Opinion
16247-23L
09-24-2024
WANRIETTA FAYE COURSEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch, Judge.
On August 16, 2024, 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 issued an Order to Show Cause on August 19, 2024, and ordered Ms. Coursel to respond by September 9, 2024. By Order served September 13, 2024, the Court made its Order to Show Cause absolute. On September 13, 2024, the Court received from Ms. Coursel a document she had titled as "Petitioner response to the courts order to show cause." A review of that document reveals that it is not a response to the Court's Order to Show Cause. Instead, it is intended as a supplement to the Administrative Record the Commissioner filed on May 1, 2024.
While all of this was occurring, the Court denied a pending Motion for Summary Judgment and remanded this case to Appeals for further consideration during which Ms. Coursel can present additional information. Accordingly, it is
ORDERED that the Clerk shall recharacterize document number 23 as Petitioner's Motion to Supplement the Administrative Record. It is further
ORDERED that Petitioner's Motion to Supplement the Administrative Record is granted in that the Commissioner shall provide this additional information to Appeals in the pending remand.