Opinion
13856-23
03-19-2024
NEIL H. GOLD & SUSAN M. MATTICK-GOLD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
`This case is on the Court's April 9, 2024 trial calendar for Buffalo, New York. Respondent moved on February 20, 2024, for an order to show cause under Rule 91(f) of the Court's Rules of Practice and Procedure. That rule requires that it be
ORDERED that respondent's motion is granted, and it is also
ORDERED that petitioners shall, on or before April 5, 2024 file responses in compliance with Rule 91(f)(2), with proof of service of a copy on opposing counsel, showing why facts and evidence set forth in respondent's proposed Stipulation of Facts, marked Exhibit A, should not be deemed accepted as established for the purpose of this case. If petitioners do not file a response, or if the response is evasive or not fairly directed to the proposed stipulation or any part of it, the Court will enter an order under Rule 91(f)(3) treating the proposed stipulation or part of a stipulation as established.