Opinion
7835-20 7835-20 7836-20 7837-20 7741-21.
02-18-2022
Armond Garibyan, et al., Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER
Mark V. Holmes Judge
These cases are 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 February 14, 2022 the parties moved to continue them again. We spoke with the parties on February 17 about how to move the cases ahead. One problem -- taxpayers trying to represent themselves in reasonably complicated cases -- was solved with the entry of appearance by an attorney. A more specific problem -- the failure of informal discovery to get the records produced that need to be produced for these cases to settle or be tried -- will shortly be solved by respondent's moving forward to formal discovery.
As the Court explained to the parties, the history of these cases would normally incline us to move them to a pretrial-order track. The arrival of representation for petitioners, however, means that keeping them on a status-report track to settlement remains a possibility. We will decide which track to move these cases onto after the completion of formal discovery. In the meantime, it is
ORDERED that the joint motion to continue these cases is granted in that they are stricken from the Court's April 4, 2022 trial calendar. It is also
ORDERED that this division of the Court retains jurisdiction.