Opinion
21310-21
09-13-2022
MOHAMMAD MOSHFEGHI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
James S. Halpern, Judge.
On September 7, 2022, at 4:12 PM (docket entry #8), and at 5:42 PM (docket entry #9), 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). The documents appear to be duplicates and the Court will strike from the record the second submission. It is, therefore, ORDERED that the September 7, 2022, at 5:42 PM (docket entry #9), 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 hereby deemed stricken from the record and shall not be viewable as part of this case. It is further
ORDERED that respondent's motion filed on September 7, 2022, at 4:12 PM, is granted. It is further
ORDERED that petitioner shall, on or before October 7, 2022, file a response in compliance with the provisions of Rule 91(f)(2), with proof of service of a copy thereof on opposing counsel, showing why the matters set forth in respondent's motion papers should not be deemed admitted for purposes of the pending 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 portion thereof, that matter or portion thereof will be deemed stipulated for purposes of the pending case, and an order will be entered accordingly, pursuant to Rule 91(f) (3).