Opinion
26889-16 26890-16 26891-16 21033-18 21034-18 21035-18
01-25-2022
NORTHERN CALIFORNIA SMALL BUSINESS ASSISTANTS INC., ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph Robert Goeke Judge.
On December 21, 2021, petitioner Dona Ruth Frank filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) with a declaration. By Order served December 21, 2021, the Court granted petitioner's motion and directed respondent on or before January 21, 2022, to file a response in compliance with the provisions of Rule 91(f), showing why the facts and evidence set forth in petitioner's proposed second stipulation of facts and exhibits attached to petitioner's motion should not be deemed admitted for the purpose of this case. On January 21, 2022, respondent filed a response. The Court notes that respondent raises valid objections in their response and the parties are to continue their negotiations on a complete supplemental stipulation of facts. The Court will direct the parties to report on the status of the supplemental stipulation of facts in the March 14, 2022, status report together with the previous information that the Court ordered on January 12, 2022. Accordingly, it is
ORDERED that the Court's Order to Show Cause, served December 21, 2021, is held in abeyance. It is further
ORDERED that the parties are directed on or before March 14, 2022, to file with the Court a status report as described above.