Opinion
610-24
09-11-2024
KAITLIN JUDY RYAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Adam B. Landy Judge.
This case is scheduled for trial at the Court's October 28, 2024, Salt Lake City, Utah, trial session. Pending before the Court is a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) Tax Court Rules of Practice and Procedure, filed September 10, 2024.
Upon due consideration of the foregoing, and for cause, it is
ORDERED that the Commissioner's Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f), filed September 10, 2024, is granted. It is further
ORDERED that, on or before October 1, 2024, Ms. Ryan shall file a response in compliance with Rule 91(f)(2), with proof of service of a copy on counsel for the Commissioner, showing why facts and evidence set forth in the Commissioner's proposed Stipulation of Facts, marked Exhibit A, should not be deemed accepted as established for the purpose of this case.
If Ms. Ryan does not file a response, or if the response is evasive or not fairly directed to the proposed stipulation or any part of it, the Court will enter an order under Rule 91(f)(3) treating the proposed stipulation or part of a stipulation as established.