Opinion
12393-20
06-29-2021
Jayson Savela Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On June 25, 2021, respondent filed in the above-docketed matter a Motion for Summary Judgment, in which respondent asserts that the case can be decided in respondent's favor because there are no genuine issues for trial and/or no material facts in dispute.
The Court will order petitioner to file a response, if any, to respondent's motion. In the response, petitioner should point out the specific facts in dispute if petitioner disagrees with the facts set forth in respondent's motion, and petitioner should state petitioner's position on the disputed legal issues if petitioner disagrees with respondent's argument as to the law.
Upon due consideration, it is
ORDERED that, on or before July 26, 2021, petitioner shall file a response, if any, to the just-described Motion for Summary Judgment. Failure to comply with this Order may result in the granting of respondent's motion for summary judgment and a decision, if appropriate, may be entered against petitioner. See Rule 121(b), Tax Court Rules of Practice and Procedure.
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