Opinion
6452-22SL
10-20-2023
QUOC TIEN HOANG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Jennifer E. Siegel Special Trial Judge.
This case is calendared for trial at the Court's December 11, 2023, San Francisco, California trial session. On October 12, 2023, respondent filed a Motion for Summary Judgment and a declaration in support of the motion. According to respondent, a trial is not necessary in this case because no relevant facts are in dispute, and, based on the facts as presented, respondent claims that the law requires the Court to decide this case in his favor.
We will direct petitioner to file a written response to respondent's motion. A response should include the specific facts or legal argument, if any, with which petitioner disagrees. More information about filing a proper response can be found on the Tax Court website at https://ustaxcourt.gov/petitioners_start.html#START39. Under Tax Court Rule 121(d), if petitioner does not file a response to the motion, the Court can enter a decision against him, ending this case in respondent's favor.
Upon due consideration, it is therefore
ORDERED that, on or before November 13, 2023, petitioner shall file with the Court a response to the above-referenced motion.