Opinion
24344-17 11352-18 25268-18
04-29-2022
SUNIL S. PATEL & LAURIE MCANALLY PATEL ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones, Judge
On February 24, 2022, respondent filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established under Rule 91(f) of this Court's Rules of Practice and Procedure. On March 4, 2022, petitioners filed an opposition to respondent's motion. On March 22, 2022, the Court granted respondent's motion and ordered that petitioners show cause on April 25, 2022 at Washington, D.C. why the matters covered in respondent's motion for order to show cause, should not be deemed admitted for purposes of this case.
This case was called for trial on April 25, 2022 for the Washington, D.C. trial session of the Court. Both parties appeared and represented that the matters covered in respondent's motion for order to show cause are resolved by the Second Stipulation of Facts, filed April 26, 2022. Upon due consideration and for cause more fully appearing in the transcript of the proceedings, it is
ORDERED that the Court's Order to Show Cause dated March 22, 2022 is discharged.