Opinion
23069-16
12-01-2022
KEVIN JOHN WITASICK, SR. & WHITNEY S. WITASICK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber, Judge.
On November 22, 2022, respondent filed a status report in this case. In the report respondent expresses concern that petitioners' current counsel may be intending to advance arguments different from those advanced by petitioners' former counsel in the pretrial memorandum (PTM) that was filed on May 23, 2022. Because this case has not been set for trial, we will not order petitioners to file a new PTM at this time. However, we expect petitioners' current counsel to inform respondent promptly if he anticipates presenting a case substantially different from that set forth in petitioners' PTM filed May 23, 2022.
Upon due consideration, it is
ORDERED that, on or before January 24, 2023, the parties shall file a status report (jointly if possible, otherwise separately) detailing the then-present status of the case. 1