Opinion
4715-21
10-04-2022
DEAN N. TUCCI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth A. Copeland Judge
This case was originally calendared for trial at the Court's Trial Session set to commence on May 23, 2022, in Chicago, Illinois. By Order of the Court dated March 17, 2022, the case was stricken for trial and jurisdiction was retained by this Division of the Court.
On September 15, 2022, respondent filed with the Court a Motion for Partial Summary Judgment and a Memorandum of Law in Support of Respondent's Motion for Partial Summary Judgment. Respondent's Memorandum of Law in Support of Respondent's Motion for Partial Summary Judgment requests that the Court determine that petitioner is estopped to deny that Direct Media Power, Inc. and Teldebt Solutions, Inc. were S corporations for the purposes of this case by application of the duty of consistency and enter partial summary judgment in favor of the respondent.
Upon due consideration, and for cause, it is
ORDERED that, on or before November 14, 2022, petitioner shall file with the Court a response to respondent's Motion for Partial Summary Judgment, filed on September 15, 2022. Failure to respond to as required by this Order may be deemed consent to the relief sought in the motion.