Opinion
17645-19
01-31-2022
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 reported last year that he's mostly satisfied his concerns on substantiation, but still has concerns about the issue of material participation. That issue may be headed to an impasse, but the parties reasonably ask for another couple months to try to work it out. It is therefore
ORDERED that on or before March 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.