Opinion
20894-19 6791-20 10830-20 17749-21 17771-21
03-10-2023
NOEL M. PARDUCCI & KENNETH L. PARDUCCI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge
On March 8, 2023, the Court held a remote pretrial conference regarding these consolidated cases. All parties appeared and were heard. After due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that the Scheduling Order served on October 3, 2022, is revised as to paragraphs 6 through 20 as follows:
6. May 12, 2023 - File motions with respect to party and non-party fact depositions.
7. June 16, 2023 - File motions to compel stipulation under Tax Court Rule 91(f) or motions to review the sufficiency of the answers or objections to requests for admission under Tax Court Rule 90(e).
8. July 28, 2023 - Completion of all depositions taken without leave of the Court.
9. August 4, 2023 - File dispositive motions, or motions to bifurcate.
10. August 25, 2023 - Lodge with the Court and exchange opening expert reports.
11. September 1, 2023 - Exchange expert witness workpapers relating to opening expert reports. Expert workpapers include:
1. Any facts, data, documents, or other information reviewed or considered by the expert witness in forming the opinions to be offered by the expert (the "Opinions"), including assumptions that the party's attorney provided and that the expert relied on in forming the Opinions;
2. Any exhibits that will be used as a summary of or support for the Opinions;
3. Copies of any sources not generally publicly available; and
4. Worksheets, schedules, and other documents reflecting computations considered by the expert in forming the Opinions.
12. October 6, 2023 - Lodge with the Court and exchange rebuttal expert reports.
13. October 13, 2023 - Exchange expert witness workpapers, as defined above, relating to rebuttal expert reports.
14. October 20, 2023 - Exchange any documents that may be relied upon at trial that were not previously stipulated or exchanged.
15. November 3, 2023 - File with the Court and exchange pretrial memoranda.
16. November 3, 2023 - File with the Court the first stipulation of facts.
17. November 9, 2023 - File motions in limine with respect to expert reports or any evidentiary issue, including motions to strike all or part of any expert report.
18. November 17, 2023 - File responses to motions in limine.
19. November 22, 2023 - File supplemental stipulations of fact.
20. December 4, 2023 (tentative until courtroom availability is confirmed) -Trial commences.