Opinion
5416-23L
08-08-2024
ANDRE DURANLEAU, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Emin Toro Judge
This case is currently calendared for trial during the Court's September 30, 2024, Portland, Oregon, trial session. On August 6, 2024, respondent filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established in Stipulation of Facts pursuant to Rule 91(f), Tax Court Rules of Practice and Procedure (Doc. 11). Respondent requests that petitioner show cause why the facts and evidence set forth in respondent's proposed Stipulation of Facts marked as Exhibit A to respondent's Motion together with exhibits should not be accepted as established for the purpose of this case. Upon due consideration, it is hereby
ORDERED that respondent's Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established in Stipulation of Facts is granted. It is further
ORDERED that, on or before August 28, 2024, petitioner shall file with the Court a response in compliance with Rule 91(f)(2), showing why paragraphs 1-16 in respondent's proposed stipulation of facts and evidence marked as Exhibit A together with the exhibits should not be deemed admitted for the purpose of this case. If no response is filed within the period specified above with respect to any matter or portion thereof, or if petitioner's response is evasive or not fairly directed to the proposed stipulation or a portion thereof, that matter or portion will be deemed stipulated for the purpose of this case, and an Order will be entered accordingly, pursuant to Rule 91(f)(3).