Opinion
24155-18
12-15-2021
Lawrence Leroy Henry Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
David Gustafson, Judge
This case was scheduled for trial during the Court's Washington, D.C., session beginning December 13, 2021; but the Court continued the trial and held a pretrial hearing on December 14, 2021, at which the Court discussed at length with the parties the issues in the case, the state of the evidence, and a schedule for further proceedings. To repeat the instructions given at the hearing, it is
ORDERED that no later than December 24, 2021, petitioner Lawrence Leroy Henry shall provide to respondent's counsel copies of his returns filed for 2004, 2005, 2006, 2007, 2009, and 2010. These will be useful for respondent's further consideration of Mr. Henry's contentions as to net operating loss carryforwards into the years at issue (2011-2014). It is further
ORDERED that no later than February 14, 2022, Mr. Henry shall provide to respondent's counsel (by thumb drive or otherwise) digitized copies of all the documents from 2004, 2005, 2009, and 2010 on which he will rely to support his contentions as to net operating loss carry-forwards. Those digitized documents shall be paginated sequentially (with "-P" numbers) after Mr. Henry's recently filed exhibits (the latest of which is Doc. 446, ending with page 4415-P) and shall be redacted to remove or obscure social security numbers, bank and credit card numbers, etc. It is further
ORDERED that promptly after February 14, 2022, respondent's counsel shall initiate with Mr. Henry communication about the expense deduction issues (based on the parties' stipulations filed so far) and shall state her questions about, and propose her conclusions about, the amount and allocation of substantiated expenses. No later than March 16, 2022, the parties shall file either a joint stipulation of these issues by the parties or else a joint status report (or, if that is not practical, then separate reports) that shall include a proposed schedule for further proceedings. If either party believes that a telephone conference with the judge would be helpful, then they may telephone the Chambers Administrator of the undersigned judge (at 202-521-0850) to initiate such a conference.