Opinion
2172-17
09-13-2021
Peter E. Barker-Homek & Shay Serdy, Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER
Albert G. Lauber Judge
This case is calendared on the Court's October 4, 2021, Los Angeles, California, trial session, to be conducted remotely via Zoomgov. With respect to petitioners' 2012-2014 tax years, the Internal Revenue Service (IRS or respondent) determined deficiencies of $64,539, $414,042, and $258,139, respectively, and accuracy-related penalties of $12,907, $82,808, and $51,627, respectively. The deficiencies result primarily from the IRS' determination that petitioners had failed to substantiate expense deductions claimed on their Schedules C, Profit or Loss From Business.
Currently before the Court is respondent's Motion for Continuance, filed September 9, 2021. Respondent represents that on August 13, 2021, petitioners submitted more than 3, 000 documents to substantiate their claimed deductions. Respondent represents that a continuance will enable him to review these documents and determine their relevance to this case. Respondent requests that we set this case for trial after December 3, 2021. Petitioners do not object to the granting of respondent's Motion. But they request that this case not be continued beyond December 3.
The Court expects to set this case for remote trial via Zoomgov during the Court's Winter trial session, set for administrative purposes in Denver, Colorado, beginning February 7, 2022. The undersigned will be presiding. If the parties believe that this case is inappropriate for a remote trial or that it will take more than one full day to try, they shall contact the chambers of the undersigned to discuss alternative trial arrangements.
In consideration of the foregoing, it is
ORDERED that respondent's Motion for Continuance, filed September 9, 2021, is granted, and this case is stricken from the Court's October 4, 2021, Los Angeles, California, trial session and is continued. It is further
ORDERED that jurisdiction of this case is retained by the undersigned. It is further
ORDERED that petitioners shall supply to respondent's counsel, by October 27, 2021, copies of any documents (not already provided to respondent) on which they would expect to rely at trial. It is further
ORDERED that the parties shall file with the Court, on or before November 12, 2021, a status report (jointly if possible, otherwise separately) detailing the then-present status of the case.