Opinion
13300-22S 7232-23S 14695-23S 11844-24S
09-18-2024
PETER J. JANANGELO, JR. & MARY ANN JANANGELO, ET AL Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Petitioners currently have four cases pending before the Court: Docket No. 13300-22S (concerning 2018), Docket No. 7232-23S (concerning 2019), Docket No. 14695-23S (concerning 2020), and Docket No. 11844-24S (concerning 2021). The cases all stem from respondent's determinations of deficiencies and I.R.C. section 6663 penalties.
On July 13, 2024, petitioners filed motions to continue the cases concerning 2018 and 2019 so that all four cases could be heard together. On July 22, 2024, the Court held a conference call with the parties during which respondent also indicated a preference to have the four cases handled together. It appears that the last of the four cases is now at issue.
Upon due consideration of respondent's Status Report filed September 9, 2024, at Docket No. 11844-24S and for cause, it is
ORDERED that the cases at Docket No. 14695-23S and Docket No. 11844-24S are no longer assigned to Special Trial Judge Jennifer E. Siegel. It is further
ORDERED that the cases at Docket No. 14695-23S and Docket No. 11844-24S are calendared for trial at the trial session of the Court scheduled to commence at 10:00 AM on December 2, 2024, at the Sandra Day O'Connor U.S. Courthouse, 401 West Washington St., Room 406, 4th Floor, Phoenix, AZ 85003. It is further
ORDERED that the above-docketed cases are consolidated for trial, briefing, and opinion. It is further
ORDERED that, together with this Order, the Clerk of the Court shall also serve on the parties in Docket No. 14695-23S and Docket No. 11844-24S copies of the Standing Pretrial Order issued in connection with the December 2, 2024, Phoenix, Arizona, trial session.