Betz v. Comm'r of Internal Revenue

Full title: Mark Betz & Christine Betz, et al Petitioners v. Commissioner of Internal…

Court: United States Tax Court

Date published: Jan 5, 2022

No. 21587-18 (U.S.T.C. Jan. 5, 2022)

Opinion

21587-18 21588-18

01-05-2022

Mark Betz & Christine Betz, et al Petitioners v. Commissioner of Internal Revenue, Respondent

JOSEPH W. NEGA, JUDGE

ORDER

JOSEPH W. NEGA, JUDGE

These consolidated cases were called for remote trial on June 21 through June 25, 2021, at a Special Session of the Court for cases in which Chicago, Illinois, was listed as the place of trial. On November 30, 2021, these consolidated cases were called for an in-person trial at a Special Session of the Court. On December 7, 2021, these consolidated cases were submitted to the undersigned. At trial, the Court reserved ruling on the admissibility of Exhibit 1703-P. After reviewing the record and considering the arguments of the parties, the Court will allow Exhibit 1703-P into evidence. The parties may, however, challenge the reliability of that exhibit and make necessary arguments in their respective briefs. All briefs shall conform to the requirements of Rule 151, Tax Court Rule of Practice an Procedure.

Upon due consideration and appearing more fully in the transcripts of this proceeding, it is ORDERED that on the Court's own motion, the record in this case is reopened. It is further

ORDERED that Exhibit 1703-P is received into evidence. It is further

ORDERED that the record in this case is hereby closed. It is further

ORDERED that, on or before February 22, 2022, the parties shall file simultaneous opening briefs, with a page limitation of fifty pages, not including the title page, table of contents, table of authorities, and certificate of service. It is further

ORDERED that, on or before April 8, 2022, the parties shall file simultaneous answering briefs, with a page limitation of twenty-five pages, not including the title page, table of contents, table of authorities, and certificate of service. It is further

ORDERED that the parties' simultaneous opening briefs shall include typewritten pages typed on only one side and shall be on plain white paper 8½ inches wide by 11 inches long. The font shall be Times New Roman size 12, and the margins shall be 1 inch on each side and no more than 22 lines per page. There shall be no attachments or exhibit and no footnotes.