Opinion
23405-21
03-24-2023
JIE GAO & CHENGJU WANG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's September 12, 2022 trial calendar for San Francisco, California. Until trial began it seemed to be a case about substantiation of travel expenses that Ms. Gao had reported on a Schedule C. During the trial, however, testimony suggested that the business was incorporated. We adjourned the trial because petitioners did not understand the importance of the question and respondent had had no way of anticipating that there would be testimony that not only the business was incorporated but that it might have been incorporated under subchapter C, engaged in a successful first round of venture-capital financing and perhaps engaged in some kind of corporate reorganization with a foreign corporation. We asked respondent to look into this tangle and either move to amend his answer or state that he did not want to. On February 17, 2023 respondent moved to amend his answer and said that petitioners opposed the motion. It is therefore
ORDERED that petitioners file a response to respondent's February 17, 2023 motion on or before April 3, 2023.