Opinion
286-21
07-17-2024
CURTIS K. KADAU & LORI A. KADAU, DECEASED, CURTIS K. KADAU, PERSONAL REPRESENTATIVE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge
On July 17, 2024, respondent filed Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established Pursuant to Rule 91(f), of the Court's Rules of Practice and Procedure. Pursuant to the provisions of that Rule, it is
ORDERED that respondent's above-referenced motion is granted. It is further
ORDERED that on or before August 6, 2024, petitioners shall file with the Court a response in compliance with the provisions of Rule 91(f)(2), with proof of service of a copy thereof on respondent, showing cause why the proposed matters as set forth in his motion, should not be deemed admitted for purposes of this pending case. If petitioners fail to file a response within the period specified above with respect to any matter or portion thereof, or if the response is evasive or not fairly directed to the proposed stipulation or portion thereof, then that matter or portion thereof, will be deemed stipulated for purposes of this pending case, and an Order will be entered accordingly, pursuant to Rule 91(f)(3) of the Tax Court Rules of Practice and Procedure.