Opinion
24790-22
03-21-2024
SAMANTHA A. CRIDER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson, Judge
In anticipation of the upcoming trial session in Columbia, South Carolina, beginning April 8, 2024, we held a telephone conference call with the parties on March 21, 2024. We discussed the steps that will be necessary to prepare the case for the trial session. Petitioner Samantha A. Crider explained that she expects to substantiate her business expenses from bank records that her bank will produce to her sometime on Monday, March 25, 2024, and that she will annotate the records to indicate the identity and nature of expenses reflected on them. As we stated orally at the conclusion of the telephone conference, it is
ORDERED that this case will be called at 10:00 a.m. on April 8, 2024, as previously noticed (see Docs. 9, 13), unless before then the parties have resolved this case in full by the filing of a stipulated decision document signed by both parties. It is further
ORDERED that the parties shall cooperate in preparing the stipulation of facts, as required by Rule 91(a) and by our standing pretrial order (Doc. 10, para. 6(A)), under which the stipulation is due March 25, 2024. From the parties' remarks at the telephone conference, it seems that at least a "bare-bones" stipulation--including agreement on the petitioner's income--can be easily reached. If they file such a bare-bones stipulation but are able thereafter to stipulate additional facts, those additional facts should be the subject of a supplemental stipulation filed before trial. It is further
ORDERED that by Tuesday, March 26, Ms. Crider shall provide to her return preparer and shall produce to the Commissioner's counsel the annotated bank records that show her deductible expenses.