Opinion
16532-21
03-20-2023
LAKE JORDAN HOLDINGS, LLC, LAKE JORDAN PARTNERS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Patrick J. Urda Judge
On February 22, 2023, petitioner Lake Jordan Holdings, LLC, Lake Jordan Partners, LLC, Tax Matters Partner (Lake Jordan) filed a motion for order to show cause why proposed facts and evidence should not be accepted as established pursuant to Rule 91(f). [Doc. 54.] Upon consideration of Lake Jordan's motion and pursuant to Tax Court Rule 91(f), it is
ORDERED that Lake Jordan's motion for order to show cause why proposed facts and evidence should not be accepted as established pursuant to Rule 91(f) [Doc. 54] is granted, and the Commissioner shall, on or before April 10, 2023, file a response in compliance with the provisions of Rule 91(f)(2), with proof of service of a copy thereof on opposing counsel, showing why the matters set forth in Lake Jordan's proposed first supplemental stipulation should not be deemed admitted for purposes of the pending case. For any item to which the Commissioner objects, the Commissioner shall reference the paragraph and exhibit number and state their specific objection. If no response is filed 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 first supplemental stipulation or portion thereof, that matter or portion thereof will be deemed stipulated for purposes of the pending case, and an order will be entered accordingly, pursuant to Tax Court Rule 91(f)(3).