Opinion
15253-20 22822-21
04-30-2024
ATKINSON, ANDELSON, LOYA, RUUD & ROMO A PROFESSIONAL LAW CORPORATION, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES JUDGE
These cases were on the Court's April 4, 2022 trial calendar for Los Angeles, California. The asserted deficiencies are large, mostly disputes about a law firm's substantiation of its expenses, and we hoped would be susceptible to settlement at IRS Appeals. We continued them to give IRS Appeals a chance to do so.
That did not work out, and progress in the case seemed to stall. We spoke with them on April 26, 2024 to check on progress and again discuss whether we had to move these substantiation cases to a pretrial-order track. We decided that we didn't need to yet.
The parties reported that informal discovery did resume after our last phone call with them. But it is still not complete. Both thought it reasonable under the circumstances to impose some deadlines. It is therefore
ORDERED that on or June 10, 2024, petitioner shall produce any remaining responses to respondent's informal-discovery requests relating to petitioner's 2016 tax year. It is also
ORDERED that on or July 22, 2024, petitioner shall produce any remaining responses to respondent's informal-discovery requests relating to petitioner's 2017 tax year. It is also
ORDERED that on or before August 5, 2024 the parties file a status report describing their progress in bringing informal discovery to a close and suggesting what kind of formal discovery, if any, each thinks will be needed.