Opinion
7835-20 7836-20 7837-20 7741-21
06-15-2022
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. We continued them because petitioners' retention of an attorney let us infer a more rapid development of the cases. Respondent had to move to formal discovery and that has been fairly productive. But we learned in a phone call with the parties on June 14, 2022 that discovery has still not come to an end. We stressed that it needs to do so if the parties are to be able to engage in productive settlement talks.
That calls for a deadline, so it is
ORDERED that on or before August 15, 2022 petitioners will deliver (and note that this is deliver, not send) to respondent's counsel assigned to these cases all records that they believe substantiate their claimed income and deductions for the tax years at issue in these cases. Any records that they do not deliver to IRS will not be allowed into evidence in any trial of these cases. It is also
ORDERED on or before September 2, 2022, the parties file a status report describing any progress toward settlement or a narrowing of the issues to be tried in these cases.