Opinion
22494-19
10-27-2021
Timothy McNamee Petitioner v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Christian N. Weiler Judge
On October 26, 2021, respondent filed (1) a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted As Established pursuant to Rule 91(f) of the Court's Rules of Practice and Procedure, and (2) a First Supplement to the Motion for Order to Show Cause attaching thereto the proposed Stipulation of Facts, marked as Exhibit A.
Pursuant to the provisions of that Rule, it is ORDERED that respondent's above-referenced motion, as supplemented, is granted. It is further
ORDERED that, on or before November 19, 2021, petitioner shall file with the Court a response in compliance with the provisions of Rule 91(f)(2), with proof of service of a copy thereof on respondent's counsel, showing cause why the matters set forth in respondent's proposed Stipulation of Facts in respondent's motion, as supplemented (marked as Exhibit A), should not be deemed admitted for purposes of this pending case. If petitioner fails to file a response 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 portion thereof, then that matter or portion thereof, will be deemed stipulated for purposes of this pending case, and an Order will be issued accordingly, pursuant to Rule 91(f)(3) of the Tax Court Rules of Practice and Procedure.