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Parducci v. Comm'r of Internal Revenue

United States Tax Court
Sep 1, 2023
No. 17749-21 (U.S.T.C. Sep. 1, 2023)

Opinion

Docket 20894-19 6791-20 10830-20 17749-21 17771-21

09-01-2023

NOEL M. PARDUCCI & KENNETH L. PARDUCCI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


SCHEDULING ORDER

Ronald L. Buch Judge

Several motions are pending in these cases. Those, along with scheduling conflicts, will necessitate that the present scheduling order be revised.

To recap, on September 30, 2022, the parties proposed a pretrial schedule and trial date. On October 3, 2022, the Court issued a scheduling order largely adopting the parties proposed schedule. Following a hearing on March 8, 2023, the Court modified the pretrial schedule and trial date in an order dated March 10, 2023. After receiving several motions, the Court issued an Order on August 10, 2023, suspending the pretrial schedule. That Order erroneously referred to the original October 3, 2022, pretrial schedule. On August 30, 2023, the Court held another hearing with the parties to discuss pending motions and the pretrial schedule. Having heard the parties' views, it is

ORDERED that the Scheduling Order served on March 20, 2023, is revised as to paragraphs 10 through 20, as follows:

10.September 15, 2023 - Lodge with the Court and exchange opening expert reports.

11.September 22, 2023 - Exchange expert witness workpapers relating to opening expert reports. Expert workpapers include:

1. Any facts, data, documents, or other information reviewed or considered by the expert witness in forming the opinions to be offered by the expert (the "Opinions"), including assumptions that the party's attorney provided and that the expert relied on in forming the Opinions;

2. Any exhibits that will be used as a summary of or support for the Opinions;

3. Copies of any sources not generally publicly available; and

4. Worksheets, schedules, and other documents reflecting computations considered by the expert in forming the Opinions.

12. October 27, 2023 - Lodge with the Court and exchange rebuttal expert reports.

13. October 27, 2023 - Exchange expert witness workpapers, as defined above, relating to rebuttal expert reports.

14. October 27, 2023 - Exchange any documents that may be relied upon at trial that were not previously stipulated or exchanged.

15. November 3, 2023 - File with the Court and exchange pretrial memoranda. 16.November 3, 2023 - File with the Court the first stipulation of facts.

17. November 9, 2023 - File motions in limine with respect to expert reports or any evidentiary issue, including motions to strike all or part of any expert report.

18. November 17, 2023 - File responses to motions in limine.

19. November 22, 2023 - File supplemental stipulations of fact.

20. December 4, 2023 - Trial commences.


Summaries of

Parducci v. Comm'r of Internal Revenue

United States Tax Court
Sep 1, 2023
No. 17749-21 (U.S.T.C. Sep. 1, 2023)
Case details for

Parducci v. Comm'r of Internal Revenue

Case Details

Full title:NOEL M. PARDUCCI & KENNETH L. PARDUCCI, ET AL., Petitioners v…

Court:United States Tax Court

Date published: Sep 1, 2023

Citations

No. 17749-21 (U.S.T.C. Sep. 1, 2023)