Opinion
12638-20L
12-23-2021
Robert J. Norberg & Debra L. Norberg Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On October 14, 2021, respondent filed in the above-docketed matter a Motion for Summary Judgment, in which respondent asserts that the case can be decided in respondent's favor because there are no genuine issues for trial and/or no material facts in dispute.
The Court will order petitioners to file a response, if any, to respondent's motion. In the response, petitioners should point out the specific facts in dispute if petitioners disagree with the facts set forth in respondent's motion, and petitioners should state petitioners' position on the disputed legal issues if petitioners disagrees\ with respondent's argument as to the law. Attached to this order is a copy of Q&As the Court has prepared on the subject "What is a motion for summary judgment?"
Upon due consideration, it is
ORDERED that, on or before January 24, 2022, petitioners shall file a response, if any, to the just-described Motion for Summary Judgment. Failure to comply with this Order may result in the granting of respondent's motion for summary judgment and a decision, if appropriate, may be entered against petitioners. See Rule 121(b), Tax Court Rules of Practice and Procedure.