Opinion
27785-21 28351-21
10-13-2022
Dmitriy V. Golovin, et al., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
These cases were both on the Court's September 12, 2022 trial calendar for San Francisco, California. Petitioners were partners who jointly owned a now-defunct business. The cases were nowhere near ready for trial because the administrative file for petitioners' corporation had not made its way to the IRS lawyers working on these cases.
Respondent recently reported that the file - with more than 5,000 pages - has now been found, redacted, and sent on to petitioners for them to begin to review. The cases may be about tracing cash flows between petitioners and the corporation, and such cases can be complicated to resolve. But the parties have started. The cases can stay on a status-report track for now, and it is
ORDERED that on the Court's own motion the above-docketed cases are consolidated for trial, briefing, and opinion. It is also
ORDERED that on or before January 9, 2023 respondent file a status report that describes the parties' progress toward settlement or a narrowing of the issues to be tried, and especially any progress in completing informal discovery.