Opinion
27796-21S
02-05-2024
MARK STEVEN ELLIS & MEGHAN ELLIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy, Special Trial Judge
This case is calendared for trial at the April 2, 2024, Detroit, Michigan Trial Session of the Court.
On August 11, 2021, petitioners filed a petition for redetermination of the deficiency for taxable year 2018. This case was set for trial on September 6, 2022. At the calendar call, Mr. Ellis requested an oral continuance to permit him to find documents substantiating the expenses incurred to reduce the gross unreported income. The Court granted the request on September 6, 2022. Since that time, the Commissioner has filed a status report outlining the difficulty he has experienced in obtaining documents from petitioners. By status report filed December 23, 2022, the Commissioner notified the Court that on October 24, 2022, Ms. Ellis provided counsel for the Commissioner with a Form 8857, Request for Innocent Spouse Relief for consideration.
The Court directs the parties to file reports: (1) identifying the specific issues remaining in dispute, (2) discussing whether the parties have met and conferred, either in person or by telephone, to discuss the issues remaining in dispute, (3) describing the efforts that the parties have undertaken or plan to undertake to settle this matter, and (4) informing the Court whether the party plans to file any pretrial motion(s) and, if so, the nature of such motion(s).
Upon due consideration and for cause, it is
ORDERED that, on or before February 27, 2024, the parties shall file written reports (jointly or separately) with the Court as more fully described in this Order. It is further
ORDERED that, on or before March 1, 2024, the parties shall file the entire administrative record (or so much of that record as either party may deem necessary for a complete disposition of the issue or issues in dispute) stipulated as to its genuineness in accordance with Rule 93, Tax Court Rules of Practice and Procedure.