Opinion
26044-21
10-30-2023
JAMES LEE MCCONNELL & CAROLYN ANNE MCCONNELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
JOSEPH ROBERT GOEKE JUDGE
On October 27, 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). Respondent appended to the Motion a proposed Stipulation of Facts with attached exhibits. Respondent requests that petitioners show cause why the facts and evidence set forth in the proposed Stipulation, marked "Exhibit A," should not be accepted as established for the purposes of this case. In consideration of the foregoing, it is
ORDERED that respondent's Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) is granted. It is further
ORDERED that petitioners shall file with the Court, on or before November 30, 2023, a response in compliance with the provisions of Tax Court Rule 91(f), with proof of service of a copy thereof on respondent's counsel, showing why the facts and evidence set forth in respondent's Stipulation should not be deemed accepted as established for purposes of this case. 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 Stipulation or a portion thereof, that matter or portion thereof will be deemed stipulated for the purpose of the pending case, and an order will be entered accordingly pursuant to Tax Court Rule 91(f).