Opinion
13924-22
04-07-2023
BRANDON TAYLOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge
This case is currently set for trial at the Court's June 5, 2023, Memphis, Tennessee, trial session. On April 5, 2023, respondent filed a Motion for Summary Judgment and to Impose a Penalty Under Section 6673 (Doc. 13). Respondent moves the Court for summary adjudication in respondent's favor upon all of the legal issues in controversy. Respondent further moves that the Court impose a penalty in an appropriate amount based upon the fact petitioner has instituted these proceedings primarily for the purpose of delay and petitioner's position in the present case is frivolous and/or groundless. Upon due consideration, it is hereby
ORDERED that, on or before May 8, 2023, petitioner shall serve on respondent, and file with the Court, a response to respondent's Motion for Summary Judgment and to Impose a Penalty Under Section 6673.
ORDERED that, no later than May 22, 2023, respondent shall file with the Court and serve on petitioners a reply to petitioners' response (or, if petitioners have failed to file and serve a response, then respondent shall file a status report).
Petitioner is advised that failure to respond as required by this Order may be deemed consent to the relief sought in the motion and may result in a decision being entered against him under Rule 121(d) of the Tax Court Rules of Practice and Procedure.