Opinion
18246-19
02-17-2022
Christopher Kinney & Kathryn Kinney Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's October 19, 2020 trial calendar for New York City. The parties recently reported that all information relevant to the Branerton Letter within Petitioners' possession had already been provided to Respondent, and that all other information relevant to the Branerton Letter would be within the possession of a third party.
On February 14, 2022 respondent moved for a document-subpoena hearing to assist the parties in obtaining documentation relevant to the issues remaining in dispute. Our rules require that it be
ORDERED that respondent's motion for a hearing is granted. It is also
ORDERED that this case is scheduled for hearing on the status of the case at the Court's March 30, 2022, Washington, D.C., special hearing session at a time certain of 1:00 p.m. (EasternTime). The Court will conduct the hearing remotely and any third-party subpoenas will be returnable at that hearing. It is also
ORDERED that the Clerk of the Court shall serve on the parties a notice of remote proceeding that shall contain comprehensive instructions on how to participate in this remote proceeding. It is also
ORDERED that, no later than March 25, 2022, respondent shall file a status report to state whether the hearing is unnecessary because the subpoenaed documents have already been produced.
Chief Special Trial Judge Lewis Carluzzo will preside at the above-referenced hearing as previously assigned by the Chief Judge. 1