Opinion
14853-20 14858-20
10-17-2022
PRITHPAL S. KANDHARI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
These cases were on the Court's April 4, 2022 trial calendar for Los Angeles, California. The combined deficiency is large, and arises mostly from ¶owthrough adjustments to the returns of an LLC owned by petitioners that was in the tire-distribution business. The parties reported a radical slowing in progress, so we spoke with them on October 13, 2022. Although petitioners are represented, we did learn that the individual petitioner most knowledgeable about the business has been seriously ill. Petitioners also reported that the records that respondent needs to review have had to be reconstructed, and that that reconstruction has been only partial. Petitioners have recently produced what they have.
Under these circumstances we agreed with the parties that it made little sense to move these cases to a pretrial-order track. We nevertheless urged them to accelerate their informal discovery. Petitioners promised to produce any records of the casualties suffered by their business by the end of this year. Respondent promised to comb through the extensive records that petitioners have already produced to have a considered opinion on whether sampling will permit progress in settlement talks or a more extensive, line-by-line review of the business's accounting will be necessary.
It is therefore
ORDERED that on or before January 20, 2023 the parties shall file a status report describing their progress toward settlement and especially in their informal discovery.