Opinion
27824-22
12-18-2023
ROCKEFELLER FINANCIAL INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Ronald L. Buch Judge
This case is calendared for trial at the Court's January 29, 2024, Phoenix, Arizona trial session. On December 15, 2023, 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). Accordingly, it is
ORDERED that the Commissioner's Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established, filed December 15, 2023, is granted. It is further
ORDERED that petitioners shall, by January 8, 2023, file a response in compliance with the provisions of Rule 91(f), showing why facts and evidence set forth in the Commissioner's proposed Stipulation of Facts attached to Commissioner's motion as Exhibit A should not be deemed admitted for the purpose of this case. If a response is not filed within the period specified above, or if the response is incomplete, evasive, or not fairly directed to the proposed stipulation, that matter may be deemed stipulated for purposes of the pending case, and an Order will be entered accordingly, pursuant to Rule 91(f)(3).