Opinion
8158-19L
10-27-2021
Luke J. Middleton Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Kathleen Kerrigan, Judge
On October 22, 2021, 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). Upon due consideration, it is
ORDERED that respondent's motion is granted, and petitioner shall, on or before November 13, 2021, show cause in writing why the facts and evidence set forth in respondent's proposed stipulation of facts should not be deemed accepted as established for the purpose of this case.