Opinion
5557-19
03-25-2022
Richard O. O'Neil, Jr Petitioner 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 reported this summer that petitioner had provided additional documentation to his accountant and prepared an amended return for tax year 2014. But then progress toward settlement slowed. We spoke with them on March 23, to discuss how to move the case forward. Petitioner said he could gather any of his remaining relevant records and get them to respondent in a month. He also promised to speak with his CPA to find out if a 2014 return for his S corporation had ever been filed. (Many of the contested items flowed through to petitioner's return from this S corporation.) And respondent promised to check the IRS's own records to see if that corporation had ever filed its return for that year.
It is time to make these deadlines begin to stick, so it is
ORDERED that on or before April 25, 2022 petitioner will deliver (and note that this is deliver, not send) to respondent's counsel all records that he believes substantiate his position for the tax year at issue in this case. Any records that he does not deliver to the IRS will not be allowed into evidence in any trial of this case. It is also
ORDERED on or before May 9, 2022 respondent shall file a status report describing any progress toward settlement or a narrowing of the issues to be tried in these cases. 1