Opinion
7835-20 7836-20 7837-20 7741-21
03-30-2022
Armond Garibyan, et al., Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER
Mark V. Holmes Judge
These cases were on the Court's April 4, 2022 trial calendar for Los Angeles, California. They involve issues of possible underreporting of gross receipts and failure to substantiate expenses for tax years that date back to 2015. On March 3, 2022 respondent moved to compel the production of documents. The request for production of documents seeks clearly discoverable information, with the exception of request number 6. That request is premature to the extent it would greatly accelerate the usual exchange of exhibits much closer to trial, and as phrased would reveal petitioners' trial-preparation strategy. It is therefore
ORDERED that respondent's motion to compel production of documents as supplemented is granted as document production requests 1-5, and petitioners shall on or before May 26, 2022 produce to counsel for respondent those documents requested in respondent's requests 1-5 for the production of documents served on petitioners on January 14, 2022. It is also
ORDERED that respondent's motion to compel production of documents as supplemented is denied as to document production request 6.