Opinion
18019-21
04-22-2022
MEHMET OMUR NAZ & FATIMA CATTANEO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge
This case is currently calendared for trial during the Court's May 9, 2022, Washington, D.C., trial session. On April 18, 2022, respondent filed a Motion for Continuance of Trial (Doc. 11).
Also on April 18, 2022, petitioner filed a Stipulation of Facts (Doc. 12). Petitioner filed a second document titled "Stipulation of Facts" (Doc. 13) that appears to be identical to the Stipulation of Facts (Doc. 12) except that the cover page is titled as "Memorandum in Support of Administrative Record." These documents are not proper stipulations of fact as they were not signed by both parties. See Rule 91(b), Tax Court Rules of Practice and Procedure.
On April 20, 2022, the Court held a conference call with the parties to discuss the current status of the case and respondent's pending motion. As agreed by the parties, although the Court expects to grant respondent's Motion for Continuance, the Court will for now hold the motion in abeyance to allow petitioners the opportunity to meet with a volunteer from a tax clinic in Washington, D.C.
Upon due consideration, it is hereby
ORDERED that petitioners' First Stipulation of Facts (Doc. 12) is hereby deemed stricken from the record in this case. It is further
ORDERED that petitioners' Memorandum in Support of Administrative Record (Doc. 13) is hereby deemed stricken from the record in this case. It is further
ORDERED that respondent's Motion for Continuance of Trial is held in abeyance.