Opinion
9154-22
01-02-2024
DIONNE GANT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Richard T. Morrison Judge
This case is calendared for trial during the Court's February 12, 2024 Trial Session in Atlanta, Georgia.
On December 27, 2023, 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).
Accordingly, it is
ORDERED that respondent's Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established, filed December 27, 2023, is granted. It is further
ORDERED that petitioners shall, by January 16, 2023, file a response in compliance with the provisions of Rule 91(f), showing why facts and evidence set forth in respondent's proposed Stipulation of Facts (attached to respondent's motion as Exhibit A) should not be deemed admitted for the purpose of this case. If a response is not filed within the period specified above, or if the response is incomplete, evasive, or not fairly directed to the proposed stipulation, that matter may be deemed stipulated for purposes of the pending case, and an Order will be entered accordingly, pursuant to Rule 91(f)(3).