Opinion
2210-20
12-22-2023
DARIUSZ J. NASIEK & SARA NASIEK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge
On December 6, 2023, petitioners filed a Notice of Concession, wherein they appear to concede (with the exception of penalties) all adjustments asserted in the notice of deficiency dated April 3, 2019. Accordingly, petitioners contend that the only issues remaining before the Court are the section 6662 accuracy-related penalties.
Numerous third-party subpoenas duces tecum were issued in this case and there remains pending a Motion to Calendar and a Motion to Compel Production of Documents filed by respondent on August 15, 2023 and September 12, 2023, respectively. In the light of petitioners' concessions, it remains unclear to the Court whether further discovery, third-party compliance with the issued/enforced subpoenas duces tecum, or a trial is necessary in this case.
Upon due consideration of the foregoing, it is
ORDERED that on or before January 18, 2024, the parties shall file a joint status report (or separate, if preferred), regarding the then-present status of this case.