Opinion
3965-20
03-15-2023
JAMES J. MAGGARD & SZU-YII CHANG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This case was on the Court's October 25, 2021 trial calendar for San Francisco, California. The two major issues are substantiation of business expenses and the possibility that the business might have lost its status as an S corporation due to disproportionate distributions. Progress toward settlement slowed, and the parties' promises to prepare the case for submission under Rule 122 have not yet been fulfilled. We spoke with them to discuss how to get the case moving, and all agreed that it can be
ORDERED that on or before March 31, 2023 the parties shall file a joint motion to submit the case for decision under Rule 122, a stipulation of settled issues, a stipulation of facts, and a proposed briefing schedule in which respondent will file first.