Opinion
23715-18
06-02-2022
THE REDI FOUNDATION, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph W. Nega Judge.
On April 11, 2022, the Court issued a memorandum opinion in this case (T.C. Memo. 2022-34). Prior to entering a decision in this case, the Court must dispose of several pending motions that the Court took under advisement at trial. On March 14, 2019, petitioner filed Petitioner's Motion to Dismiss. On March 26, 2019 petitioner filed Petitioner's Motion for Order to Show Cause Why the Counsel for the IRS, Attorney Lenius, Will Not Allow Petitioner to Take Part in the Stipulation Process to Contribute Facts and Exhibits to the Stipulation (petitioner's Motion for Order to Show Cause). On March 28, 2019, respondent filed Respondent's Motion in Limine.
Petitioner's Motion to Dismiss and Motion for Order to Show Cause are both meritless, and we will deny them. Given the Court's evidentiary rulings at trial and the issuance of the Court's memorandum opinion, we will deny Respondent's Motion in Limine as moot.
Upon due consideration and for cause, it is
ORDERED that Petitioner's Motion to Dismiss, filed March 14, 2019, is denied. It is further
ORDERED that Petitioner's Motion for Order to Show Cause Why the Counsel for the IRS, Attorney Lenius, Will Not Allow Petitioner to Take Part in the Stipulation Process to Contribute Facts and Exhibits to the Stipulation, filed March 26, 2019, is denied. It is further
ORDERED that Respondent's Motion in Limine, filed March 28, 2019, is denied as moot.