Opinion
7062-20
03-23-2022
Steven S. Carter Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
MARK V. HOLMES, JUDGE
This case is on the Court's April 4, 2022 trial calendar for Los Angeles, California. On March 4, 2022, petitioner moved without opposition for a third general continuance. We spoke with the parties on March 18 to discuss the motion. The case is about substantiation, mostly substantiation of business expenses governed by IRC § 274. Such cases are usually susceptible to settlement if records are exchanged in a timely manner. In the phone call we learned that, since this case was begun, petitioner has produced no documents to respondent's counsel. While the pandemic and petitiioner's own health problem in previous years account for some of this delay, it does not excuse all of it. We explained to the parties that we could be a bit flexible about enforcing the rule that proposed exhibits must be exchanged two weeks before calendar call -- for example, by setting trial late in the week and making the two-week rule apply to the date of trial. But there will be no further continuances, and it is
ORDERED that petitioner's March 4, 2022 motion for a continuance is denied.