Opinion
10508-21
03-13-2023
ZOFIA KRASZEWSKA, Petitioner & SIMON P. RICKS, JR., Intervenor, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Juan F. Vasquez, Judge
This case is calendared for trial at the Court's May 1, 2023, Los Angeles, California, trial session. On March 7, 2023, respondent filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established Pursuant to Rule 91(f), Tax Court Rules of Practice and Procedure. Respondent states that, while petitioner does not object to the Motion, intervenor does. Upon due consideration, it is
ORDERED that respondent's Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established, filed March 7, 2023, is granted. It is further
ORDERED that intervenor shall, by March 30, 2023, file a response in compliance with the provisions of Rule 91(f), showing why facts and evidence set forth in respondent's proposed Stipulation of Facts attached to respondent's Motion as Exhibit A should not be deemed admitted for the purpose of this case. If a response is not filed within the period specified above, or if the response is incomplete, evasive, or not fairly directed to the proposed stipulation, that matter may be deemed stipulated for purposes of the pending case, and an Order will be entered accordingly, pursuant to Rule 91(f)(3).