Opinion
30404-21L
10-31-2023
ORDER
Courtney D. Jones, Judge.
This case is on the calendar of the Court's November 13, 2023, trial session for Houston, Texas. On October 31, 2023, respondent filed the Administrative Record (Doc. 16) and the Notice of Filing of the Administrative Record (Doc. 17). Under Tax Court Rule 93(a), the Administrative Record was to be filed on August 11, 2023. Respondent has not explained why the Administrative Record was filed late and without a Motion for Leave to File Out of Time. In view of the foregoing, it is
ORDERED that respondent's Notice of Filing of the Administrative Record is recharacterized as "Motion for Leave to File Out of Time Administrative Record." It is further
ORDERED that the Motion for Leave to File Out of Time Administrative Record is denied as moot. It is further
ORDERED that, on or before November 17, 2023, petitioner may file a Motion to Complete or Supplement the Administrative Record per Tax Court Rule 93(b).