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Careretire, Inc. v. Comm'r of Internal Revenue

United States Tax Court
Mar 8, 2022
No. 6034-20 (U.S.T.C. Mar. 8, 2022)

Opinion

6034-20 6038-20

03-08-2022

CARERETIRE, INC 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. They've had two continuances so far, and on March 2, 2022 the parties moved for a third. We spoke with the parties on March 7, 2022 to discuss how to get the cases ready for settlement or trial. The immediate problem is with informal discovery -- with Covid and bureaucratic delays, respondent had not completed the retrieval and production of his administrative file until a couple months ago. He has also not yet sent his own informal requests for discovery to petitioner in one of the cases. Petitioners explained that they have not fully responded to informal discovery and that some part of their records are in the hands of a possibly noncooperating third party.

This is a not entirely satisfactory state of pretrial preparation and we explained that it is now reasonable to impose some deadlines. It is therefore

ORDERED that the above-docketed cases are consolidated for trial, briefing, and opinion. It is also

ORDERED that the parties' March 2, 2022 motion for a continuance is granted in 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 March 21, 2022 respondent shall make any remaining informal discovery requests of petitioners. It is also

ORDERED that on or before April 4, 2022 petitioners shall respond to any outstanding requests for informal discovery. It is also

ORDERED that on or before May 2, 2022 the parties shall file a status report to state their respective positions on the need for any formal discovery, especially including any third-party discovery, as well as a proposed timeline and plan to bring the case to settlement or trial.


Summaries of

Careretire, Inc. v. Comm'r of Internal Revenue

United States Tax Court
Mar 8, 2022
No. 6034-20 (U.S.T.C. Mar. 8, 2022)
Case details for

Careretire, Inc. v. Comm'r of Internal Revenue

Case Details

Full title:CARERETIRE, INC Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court:United States Tax Court

Date published: Mar 8, 2022

Citations

No. 6034-20 (U.S.T.C. Mar. 8, 2022)