Opinion
12784-18
02-22-2024
VICTORIA JOY LE BEAU, PETITIONER AND CHARLES PAUL LE BEAU, INTERVENOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall Judge
Pending before the Court in this case are (1) respondent's Motion for Partial Summary Judgment, filed March 13, 2023, and (2) intervenor's Motion to Compel Discovery and Request Sanctions, filed May 10, 2023. Premises considered, it is
ORDERED that, pursuant to Rule 93, Tax Court Rules of Practice and Procedure, the parties shall file with the Court, on or before April 8, 2024, the entire administrative record (or so much of that record as either party may deem necessary for a complete disposition of the issue(s) in dispute, stipulated to its genuineness. If the parties are unable to file a stipualted administrative record, respondent must file the entire administrative record appropriately certified by the Commissioner or by an official authorized to act for the Commissioner.