Opinion
7914-22
11-01-2022
JEFFREY A. HARTMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
On October 31, 2022, respondent filed a Motion for Summary Judgment (motion) asserting that there was not any dispute as to any genuine issue of material fact remaining for trial. That same day, respondent filed a Declaration of Eric O. Young in Support of Motion for Summary Judgment, and a second Declaration of Denise D. Davis in Support of Motion for Summary Judgment (declarations). Respondent noted in his motion that petitioner's views to the granting of the motion are unknown. The Court will direct petitioner to file a written objection to respondent's motion. If petitioner does not file an objection the Court may grant respondent's motion.
By order served October 31, 2022, respondent's motion was assigned to the undersigned for disposition. Upon due consideration, it is
ORDERED that, on or before November 16, 2022, if petitioner objects to respondent's Motion for Summary Judgment, petitioner shall file a written objection with the Court. Any objection shall specify precisely those assertions that petitioner disagrees with and the basis for the disagreement.