Opinion
2240-22S
12-01-2023
JAMES A. FRASER & REBECCA K. FRASER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph Robert Goeke Judge.
Pending before the Court is petitioners' Motion for Summary Judgment, filed September 29, 2023, and supplemented on October 30, 2023. On November 30, 2023, respondent filed a Response to Motion for Summary Judgment. Respondent alleges that petitioners failed to provide documentation for their claimed business expenses. This is a factual issue that needs to be resolved at trial. Petitioners have not submitted copies of any substantiation with their motion. Therefore, there is no basis to determine if they have properly substantiated the expenses. Accordingly, it is
ORDERED that petitioners' Motion for Summary Judgment, as supplemented is denied.