Opinion
16021-16
07-06-2022
MICHAEL G. PARKER & JULIE A. PARKER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph W. Nega Judge
This case was previously calendared for trial at the Court's April 20, 2020, San Francisco, California, trial session. By Order dated March 17, 2020, that trial session was cancelled due to concerns relating to coronavirus (COVID-19), and this case was continued and assigned to the undersigned judge.
In various filings, the parties represented that they anticipate that this case will be submitted under Rule 122. On May 16, 2019, the parties filed a Stipulation of Settled Issues. On May 29, 2020, the parties filed First Supplemental Stipulation of Settled Issues. On January 6, 2021, the parties filed a Second Supplemental Stipulation of Settled Issues. On January 31, 2022, the parties filed a First Stipulation of Facts in this case.
Unless otherwise indicated, all statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.
On June 30, 2022, the parties filed a Motion to Submit Case Pursuant to Rule 122.
Upon due consideration and for cause, it is
ORDERED the parties' Motion to Submit Case Pursuant to Rule 122 filed June 30, 2022, is granted. It is further
ORDERED that on or before September 28, 2022, the parties shall file their respective Simultaneous Opening Briefs. It is further
ORDERED that on or before November 14, 2022, the parties shall file their respective Simultaneous Answering Briefs. It is further
ORDERED that the parties' respective Simultaneous Briefs shall include typewritten pages typed on only one side and shall be on plain white paper 8½ inches wide by 11 inches long. The font shall be Century Schoolbook size 12, and the margins shall be 1 inch on each side and no more than 22 lines per page. There shall be no attachments or exhibits.