Opinion
20894-19 6791-20 10830-20 17749-21 17771-21
07-13-2023
NOEL M. PARDUCCI & KENNETH L. PARDUCCI, ET AL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge.
This case is tentatively calendared for trial in December 2023, in Portland, Oregon. On July 12, 2023, the Commissioner filed a Motion for Document Subpoena Hearing. The Commissioner has discussed this motion and the need for a document subpoena hearing with the parties, and Mr. Simpson has indicated he objects to the motion. The Commissioner's motion makes sufficient showing that the discovery is relevant to the pending case. See Rule 70. Accordingly, it is
ORDERED that the Commissioner's Motion for Document Subpoena Hearing filed July 12, 2023, is granted. It is further
ORDERED that this case is scheduled for hearing on the status of the case at the Court's August 16, 2023, Washington, DC, special hearing session to be conducted remotely at a date and time certain of 1:00 p.m. (Eastern Time) on Wednesday, August 16, 2023, at which any third-party subpoenas may be returnable. It is further
ORDERED that the Clerk of the Court shall serve on the parties a Notice of Remote Proceeding that shall contain comprehensive instructions on how to participate in the above-referenced remote proceeding. It is further
ORDERED that, no later than August 10, 2023, the Commissioner shall file a status report advising the Court whether the third-party has complied with the subpoena and a hearing is no longer necessary.
Special Trial Judge Landy will preside at the above-referenced hearing as previously assigned by the Chief Judge.