Opinion
7835-20 7836-20 7837-20 7741-21
09-06-2022
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. Document production should now be ended, and respondent reasonably asks for two months to review the documents and discuss possible settlement with petitioners. Both parties should be aware, however, that this division of the Court has a trial session in Los Angeles at the end of January 2023 and is strongly inclined to add these cases to that session if they do not settle. In the meantime it is
ORDERED that on or before October 28, 2022 the parties file a status report describing any progress toward settlement or a narrowing of the issues to be tried in these cases.