Opinion
2251-23SL
10-11-2023
BRYAN E. KIENTZ & DEBORAH S. KIENTZ, Petitioners 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 6, 2023, respondent filed a Motion for Summary Judgment. According to the motion, 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 petitioners to file a written response to respondent's motion. A response should include the specific facts or legal argument, if any, with which they disagree. 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 petitioners do not file a response to the motion, the Court can enter a decision against them, ending this case in respondent's favor.
Upon due consideration, it is therefore
ORDERED that, on or before November 1, 2023, petitioners shall file with the Court a response to the above-referenced motion.