Opinion
3488-20S
07-11-2022
DONALD S. AHAIWE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo, Chief Special Trial Judge
This case for the redetermination of a deficiency is before the Court on respondent's motion to reopen the record, filed June 21, 2022. In his motion, respondent requests that the record in this case be reopened for the limited purpose of receiving into evidence the bank records, bank record declaration, and declaration by Amy Pountain, an employee at Midland Funding, LLC, attached as Exhibits A, B, and C, respectively, to the motion. Although the documents are subject to a timely subpoena, the documents were not received until after the matter was tried and submitted on April 25, 2022.
Premises considered, and for cause more fully appearing in the above-referenced motion, it is
ORDERED that respondent's motion is granted, and the trial record in this case is reopened. The case is no longer under submission. It is further
ORDERED that this case is calendared for further trial to provide the parties the opportunity to submit additional evidence at the October 17, 2022, Los Angeles, California, trial session of the Court for a time and date certain of 11:00 a.m. on October 19, 2022, in Room 1167 at the Edward R. Roybal Center & Federal Building, 255 E. Temple Street, Los Angeles, CA, 90012. It is further
ORDERED that the terms and conditions of the Standing Pretrial Order previously served upon the parties remain in full force and effect.