Opinion
5806-21
11-22-2021
Georgina Owusu Petitioner v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
PATRICK J. URDA, JUDGE
This case is presently calendared on the Court's Columbus, Ohio, remote trial session, which is scheduled to begin January 31, 2022.
On November 12, 2021, the Commissioner filed a motion for order to show cause why proposed facts and evidence should not be accepted as established pursuant to Rule 91(f). In his motion, the Commissioner requests that petitioner Georgina Owusu explain in writing why the facts and evidence set forth in the proposed Stipulation of Facts, which is marked "Exhibit A" to the motion, should not be accepted as established for the purpose of this case.
Upon due consideration, it is
ORDERED that the Commissioner's motion to show cause, filed November 12, 2021, is granted, and Ms. Owusu shall, on or before December 6, 2021, file a response that complies with the provisions of Tax Court Rule 91(f), with proof of service of a copy thereof on opposing counsel. Specifically, she should explain in writing why the facts and evidence set forth in respondent's proposed stipulation of facts, marked "Exhibit A" to respondent's motion, should not be deemed to be established for purposes of this case. If no response is filed within the period specified above with respect to any matter or portion of the proposed stipulation of facts, or if the response is evasive or not fairly directed to the proposed stipulation or portion thereof, that matter or portion will be deemed stipulated for the purpose of the pending case, and an Order will be issued accordingly pursuant to Tax Court Rule 91(f).