Opinion
37240-21S
12-05-2022
WILLIAM DANIEL GILLAM & ILKE GILLAM,Petitioners v. COMMISSIONER OF INTERNAL REVENUE,Respondent
ORDER
ADAM B. LANDY SPECIAL TRIAL JUDGE
Pending before the Court are petitioners' Motion to Proceed Remotely and Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not Be Accepted as Established Pursuant to Rule 91(f) ("Rule 91(f) Motion"), both filed October 27, 2022. In petitioners' Rule 91(f) Motion, they argue that they have attempted to cooperate and communicate with respondent to resolve this case without a trial or if a trial is necessary, comply with Rule 91 of the Tax Court Rules of Practice of Procedure.
On November 30, 2022, respondent filed a response stating that petitioners' case was forwarded to his Independent Office of Appeals for resolution after filing his answer. While the case has been pending, respondent further argues that petitioners have not contacted him for any informal consultation or communication, and he has not refused to participate in any informal consultation, communication, or conference with petitioners contrary to the statements made in the Rule 91(f) Motion.
Upon due consideration of petitioners' motions and for cause, it is
ORDERED that, on or before January 15, 2023, petitioners and respondent shall meet and confer, by telephone or in person, regarding the Rule 91(f) Motion and the issues raised in the notice of deficiency dated September 13, 2021, as a whole. It is further
ORDERED that, on or before January 31, 2023, the parties shall electronically file a proposed stipulated decision or status report (preferably a joint report) to inform the Court of the then-present status of this case. It is further
ORDERED that petitioners' above-referenced motions are taken under advisement.