Opinion
24344-17 11352-18 25268-18
04-22-2022
SUNIL S. PATEL & LAURIE MCANALLY PATEL, ET AL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
This consolidated case is scheduled for trial at a special session of the Court, to commence on April 25 and May 23, 2022, at the U.S. Tax Court, South Courtroom, in Washington, D.C.
I. Courtroom
The undersigned understood that each party intended to bring 33 boxes of exhibits to trial. However, during a conference call with the parties on April 20, 2022, the Court was informed that each party intends to bring an additional 22 boxes.
In light of this information and upon further consideration, we will move the trial scheduled to commence on April 25, 2022, to the Center Courtroom where there will be ample space for each party's boxes.
Each party should place their boxes on their respective sides of the courtroom. Boxes should not encroach upon the working spaces of the trial clerk or the Court Reporter, and should not be near the witness stand or the bench.
Currently, the further trial, scheduled to commence May 23, 2022, will remain in the South Courtroom.
II. Pending Items
On March 22, 2022, we granted respondent's Motion for Order to Show Cause, and directed petitioners to show cause at the trial scheduled to commence on Monday, April 25, 2022. On April 18, 2022, respondent filed a Motion for Leave to file Motion in Limine. Petitioners filed an Opposition thereto on April 19, 2022. We will hear the parties and resolve the aforementioned items at the commencement of trial on April
III. Supplemental Stipulations
During the conference call on April 20, 2022, the parties advised that they plan to file a Second, Third, and Fourth Stipulation of Facts, but that there are approximately 20 reserved objections. Though we may hear the parties on those objections on Monday. April 25, we may prefer to rule on them if or when any exhibit, to which an objection has been reserved, is formally offered during trial.
IV. Schedule
The trial will begin promptly at 10:00 a.m. on Monday, April 25, 2022, and at 9:00 a.m. throughout the remainder of the week. Further, we intend to recess for a 45-minute lunch each day, and to conclude each day's work at 5 PM.
Accordingly, it is
ORDERED that the place of trial for the April 25, 2022, special trial session of the Court is changed from the South Courtroom to the Center Courtroom, United States Tax Court, 400 Second Street NW, Washington, D.C. 20217.