Opinion
5101-23S
08-29-2024
LINDA S. TAYLOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch, Judge.
This case is calendared for trial at the Court's December 9, 2024, Cleveland, Ohio trial session. On August 27, 2024, the Commissioner filed a Motion for Partial Summary Judgment. The motion indicates Ms. Taylor objects to the granting of this motion.
We will order petitioner to respond. If Ms. Taylor disagrees with the facts set forth in Commissioner's Motion for Summary Judgment, then she should point out the specific facts in dispute and explain why those facts are in dispute. In her response, Ms. Taylor should also set forth her position on the disputed legal issues. The Court has prepared questions and answers on the subject "What is a motion for summary judgment? How should I respond to one?" which can be found on the Court's website at, https://www.ustaxcourt.gov/petitioners_start.html#START40 .
Failing to respond to the Commissioner's motion (and this Order) may result in a decision being entered for the Commissioner. See Rule 121(d), Tax Court Rules of Practice and Procedure. To provide petitioner the opportunity to respond to the Commissioner's Motion, it is
ORDERED that, by September 20, 2024, the petitioner shall file with the Court a response to the Commissioner's Motion for Partial Summary Judgment.