Opinion
7535-20
04-25-2024
STEPHEN C. JOHNSON & SHILPA P. JOHNSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This case was on the April 4, 2022 Los Angeles, California trial calendar and stems almost entirely from issues of substantiation. In granting a third motion for continuance we put the parties under some deadlines for discovery and production of documents. We then ordered the Johnsons to produce documents under threat of preclusion if they did not. In his last status report, however, respondent again reported a slowing of progress.
We spoke with the parties today to discuss how to bring this case to a conclusion. Petitioners say that all issues but one have settled and, with a bit more discussion, that one issue should be capable of settlement within a month. Respondent suspected that petitioners' stated views reflected only some earlier settlement talks. We observed that the parties have not filed a stipulation of settled issues.
We did agree that that the parties should speak with each other within the next month in a last effort to settle. We stressed that if they neither settled nor filed a stipulation resolving all issues in the case, we would try to put this case on the first Los Angeles trial calendar this fall.
It is therefore
ORDERED that on or before May 22, 2024 the parties shall submit settlement documents or file a stipulation resolving all issues or file a status report stating their updated predictions of the time it will take to try this case.