Opinion
8499-21S
04-27-2022
RAFAEL D. GUTIERREZ & LINDSAY GUTIERREZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Lewis R. Carluzzo Chief Special Trial Judge
This case for the redetermination of a deficiency is before the Court on respondent's motion for summary judgment, filed February 23, 2022. Respondent's motion was called for hearing on April 25, 2022, during the Los Angeles, California, trial session that began on that date. Counsel for respondent appeared and was heard. There was no appearance by or on behalf of petitioners.
Premises considered, and for cause set forth more fully in the transcript of the above-referenced proceedings, it is
ORDERED that respondent's motion is taken under advisement. It is further
ORDERED that on or before May 25, 2022, petitioners show cause in writing why respondent's motion should not be granted.