Opinion
7535-20
02-15-2023
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. They recently reported that the Johnsons had not yet produced all that they had. It is time for a firmer deadline, so it is
ORDERED that on or before April 7, 2023 petitioners will produce to respondent's counsel all remaining records that they believe substantiate their claimed deductions for the tax years at issue in this case. Any records that they do not produce to the IRS will not be allowed into evidence in any trial of this case. It is also
ORDERED that on or before May 8, 2023 the parties shall submit settlement documents or file a status report describing their progress.