Opinion
14853-20 14858-20
03-20-2023
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 flowthrough adjustments to the returns of an LLC owned by petitioners that was in the tire-distribution business. We spoke with them last October to urge 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. They recently reported they are exchanging written analyses of their respective positions, and remain optimistice that the cases will settle. They reasonably suggest reporting again in April and it is
ORDERED that on or before April 24, 2023 the parties shall file a status report describing their progress toward settlement.