Opinion
15253-20 22822-21
02-16-2022
ATKINSON, ANDELSON, LOYA, RUUD & ROMO A PROFESSIONAL LAW CORPORATION, ET AL Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES JUDGE
These cases are on the Court's April 4, 2022 trial calendar for Los Angeles, California. The asserted deficiencies are large, so we spoke to the parties on February 14, 2022 to discuss how to get them ready for settlement or trial. It seems the cases arise mostly from substantiation issues. Petitioner explained that the pandemic greatly slowed the assembly and exchange of records, but that the ebbing of the pandemic has enabled that assembly to proceed.
All agree that settlement, or at least a narrowing of any issues to be tried, is highly likely if both cases can be referred to IRS Appeals for a while. That is a reasonable plan, and it is therefore
ORDERED that that these cases are stricken from the Court's April 4, 2022 trial calendar. It is also
ORDERED that this division of the Court retains jurisdiction. It is also
ORDERED that on or before May 13, 2022 the parties shall file a status report describing their progress toward settlement at IRS Appeals.