Opinion
5188-19
02-02-2023
ABDO SALEH & SAYADA SALEH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Ronald L. Buch Judge
This case is calendared for trial at the Court's March 13, 2023, Detroit, Michigan trial session. On January 27, 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 Fact sand Evidence Should Not Be Accepted as Established, filed January 27, 2023, is granted. It is further
ORDERED that petitioners shall, by February 17, 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).