Opinion
23276-18
09-13-2021
Rudy Flores & Janie Flores, Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER
Courtney D. Jones Judge
On August 10, 2021, respondent filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f). On August 18, 2021, the Court granted respondent's Rule 91(f) motion and entered an Order to Show Cause, which called on petitioners to file a response showing cause as to why the facts and evidence set forth in the proposed Stipulation of Facts attached to respondent's motion should not be deemed established. On September 7, 2021, petitioners timely filed their response to the Court's Order to Show Cause. Upon due consideration, it is
Unless indicated otherwise, all Rule references are to the Tax Court Rules of Practice and Procedure.
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ORDERED that paragraphs 1-7 and 9-26, including any exhibits referenced therein, of the proposed Stipulation of Facts attached to respondent's motion, filed on August 10, 2021, are deemed established (i.e., stipulated). It is further
ORDERED that, to the extent petitioners intend to present at trial attachments 1, 4, 5, and 6 referenced in paragraph 27 of their response to the Order to Show Cause or any other documentary evidence not otherwise deemed stipulated by the preceding paragraph, petitioners shall follow the procedures set forth in the Court's Standing Pretrial Order issued on April 27, 2021, as well as the Court's guidance regarding documentary evidence for remote proceedings, which is published on the Court's website. It is further
ORDERED that the Court's Order to Show Cause dated August 18, 2021, is hereby made absolute.