Opinion
14952-22
09-10-2024
JASON PAUL LOVELESS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Alina I. Marshall Judge
This case is calendared for trial at the Court's October 21, 2024, standalone remote trial session. On September 5, 2024, respondent filed with the Court a Motion For Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f). Premises considered, it is
ORDERED that respondent's above-referenced motion is granted. It is further
ORDERED that petitioner shall, on or before October 7, 2024, file a response in compliance with the provisions of Rule 91(f), Tax Court Rules of Practice and Procedure, showing why facts and evidence set forth in the respondent's proposed Stipulation of Facts attached to their motion as Exhibit A, and proposed trial exhibits 1-J through 6-J, should not be deemed admitted for the purpose of this case. If a response is not filed within the period specified above, or if the response is incomplete, evasive, or not fairly directed to the proposed stipulation, that matter may be deemed stipulated for purposes of the pending case, and an Order will be entered accordingly, pursuant to Rule 91(f)(3), Tax Court Rules of Practice and Procedure.