Opinion
19714-16
01-27-2023
CLAIR R. COUTURIER, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
This case is calendared for trial at a special session in Seattle, Washington, beginning May 30, 2023. On December 15, 2022, respondent filed a Request for Admissions. On January 13 and 19, respectively, petitioner filed a Response and an Amended Response to that request. On January 25 respondent filed a Motion and an Amended Motion to Review the Sufficiency of Answers or Objections to his Request for Admissions.
On the basis of representations in respondent's amended Motion, it appears that petitioner has not responded in a forthright manner to respondent's Request for Admissions or to his several attempts to finalize with petitioner a stipulation of facts. We will direct a response from petitioner in which he shall demonstrate with specificity that he is diligently and in good faith "attempt[ing] to attain the objectives of [respondent's] request[s] through informal consultation or communication." Tax Court Rule 90(a). If, after the filing of petitioner's response, respondent is not satisfied with the progress being made toward finalization of a stipulation of facts, he may file a motion pursuant to Tax Court Rule 91(f) and/or move for appropriate sanctions.
Upon due consideration, it is
ORDERED that petitioner shall file, on or before February 17, 2023, a Response to respondent's amended Motion to Review the Sufficiency of Answers or Objections to his Request for Admissions.