Opinion
14767-22W
10-12-2022
DENIS M. FRANKENBERGER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 18, 2022, respondent filed a Motion to Stay Proceedings.
By Order served August 19, 2022, the Court directed petitioner to file under seal a response to that Order and therein identify the third-party taxpayer(s) to whom petitioner's claims in this case relate (target taxpayer(s)). No response has been received from petitioner.
Upon due consideration of the foregoing, it is
ORDERED that the due date for petitioner to file under seal a response to the Court's Order served August 19, 2022, identifying the target taxpayer(s) in this case is extended to November 4, 2022. Documents to be filed under seal shall be submitted to the Court in paper form. It is further
ORDERED that, on or before November 4, 2022, petitioner shall file an Objection (separately from the response described above), if any, to respondent's above-referenced motion. Failure to file an objection may result in the granting of respondent's motion.
Petitioner's attention is invited to Rule 123, Tax Court Rules of Practice and Procedure, which provides that the Court may dismiss a case for failure of a petitioner to comply with orders of the Court.