Opinion
20923-22L
08-15-2023
OSVALDO LOPEZ & ANA LOPEZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
This case is on the calendar of the Court's November 27, 2023, trial session for Dallas, Texas. On August 14, 2023, respondent filed the Administrative Record (Doc. 8). Tax Court Rule 93(a) states that the parties must file "the entire administrative record (or so much of that record as either party may deem necessary for a complete disposition of the issue or issues in dispute) stipulated as to its genuineness. If, however, the parties are unable to file a stipulated administrative record, the Commissioner must file with the Court. . . .the entire administrative record, appropriately certified as to its genuineness. (Emphasis added).
The Administrative Record is neither stipulated to nor certified as to its genuineness. Upon due consideration, it is
ORDERED that, on or before August 22, 2023, respondent shall file a stipulation (if so applicable) or certificate for the Administrative Record pursuant to Tax Court Rule 93(a).