Opinion
14017-21
08-08-2024
RAMESH C. KAPUR & CHANDA KAPUR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Cary Douglas Pugh Judge
This case was stricken from the Court's June 12, 2023, Milwaukee, Wisconsin trial session and continued, and jurisdiction was retained by this Division of the Court. The Court directed the parties to file Status Reports by October 15, 2024. On August 5, 2024, respondent filed a Motion for Leave to File a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) and lodged a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f). Attached as "Exhibit A" to that motion was a copy of the proposed Stipulation of Facts. Upon due consideration and for cause, it is hereby
ORDERED that respondent's Motion for Leave to File a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f), filed August 5, 2024, is granted. It is further
ORDERED that respondent's Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f), lodged August 5, 2024, is filed as of the date of this Order, and granted. It is further
ORDERED that petitioners shall, on or before September 9, 2024, file a response in compliance with the provisions of Rule 91(f)(2), with proof of service of a copy on respondent, showing why the matters set forth in respondent's motion for order to show cause should not be deemed admitted for purposes of the pending case. If no response is filed with the Court 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, such matter or portion thereof shall be deemed stipulated for purposes of the pending case, and an order entered accordingly, pursuant to Rule 91(f)(3).