Opinion
24155-22SL
09-12-2023
PATRICIA ANNE RICKER & DANIEL RICKER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
This case is calendared for trial at the Court's standalone remote trial session scheduled to commence on November 13, 2023. On September 11, 2023, the Commissioner filed a Motion for Summary Judgment seeking summary adjudication in his favor upon all issues presented in the case. The Commissioner also stated he does not know whether the Rickers object to the Court granting the Motion.
If the Rickers disagree with the facts set forth in paragraphs four (4) through twenty (20) of the Commissioner's Motion, then they should state the specific facts in dispute and explain why those facts are in dispute. If the Rickers disagree with the Commissioner's arguments as to the law, then their response should also set forth their position on the disputed legal issues. The Court has prepared questions and answers on the subject "What is a motion for summary judgment? How should I respond to one?" which can be found on the Court's website at www.ustaxcourt.gov and on the printed page attached to this Order.
The foregoing considered, it is
ORDERED that, on or before October 12, 2023, the Rickers shall file a response to the Commissioner's above-referenced Motion. Failure to comply with this Order may result in the granting of the Motion. See Rule 121(d).
The Rickers are reminded of possible assistance available to respond to this Order through low-income taxpayer clinics which can be found on the Court's website at https://www.ustaxcourt.gov/clinics.html and a list is also attached to this Order.