Opinion
11455-20L
02-28-2022
Kevin T. Lipka & Shelly Z. Lipka Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
David Gustafson Judge
Trial in this case was scheduled to begin March 28, 2022 (see Doc. 12), and our Standing Pretrial Order (Doc. 13) set deadlines of March 7, 2022, for pretrial memoranda and March 14, 2022, for the joint stipulation of facts. The Commissioner filed a motion (Doc. 14) for summary judgment, for which we ordered (see Doc. 16) a briefing schedule that will be concluded March 4, 2022--only 24 days before trial. It is uncertain whether we can rule on the motion before March 28, and it is almost certain that we will not be able rule on it before March 7. Petitioners have filed a motion (Doc. 18) for a continuance, and the motion states that the Commissioner objects. It is
ORDERED that, no later than March 4, 2022, the Commissioner shall file a response to the motion for a continuance.