Opinion
17645-19
11-29-2021
Ted H. Franse Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's October 25, 2021 trial calendar for San Francisco, California. We continued it to enable the parties to try to make progress through settlement in informal discovery. Respondent did so and in his recent status report stated that he's mostly satisfied his concerns on substantiation, but still has concerns about the issue of material participation. These may be resolved through additional discovery, so it is
ORDERED that on or before January 24, 2022 the parties submit settlement documents or file a joint status report describing their progress toward settlement or a narrowing of the issues to be tried, as well as their respective positions on the need for further discovery.