Opinion
10748-22S
03-08-2023
JARVEZ DUPREE HALL & ADRIANA ZUNIGA HALL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo, Chief Special Trial Judge
This case for the redetermination of a deficiency, presently set for trial during the Portland, Oregon, trial session scheduled to begin on April 11, 2023, is before the Court on petitioners' motion to proceed remotely, filed March 6, 2023. According to the motion, respondent objects. Allegations in the petition and the copy of the notice of deficiency attached to the petition show that various deductions claimed on petitioners' 2018 federal income tax return are in dispute in this case. As best as can be determined from the record at this stage of the proceedings, the deductions in dispute have been disallowed because petitioners have failed to substantiate them.
Because a trial focusing on substantiating disallowed deductions does not lend itself to a trial conducted remotely, because it appears that petitioners' residence is less than ten miles from the courthouse, and because respondent has objected to the motion, it is
ORDERED that petitioners' motion is denied.