Opinion
24344-17 11352-18 25268-18
03-30-2022
SUNIL S. PATEL & LAURIE MCANALLY PATEL, ET. AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones, Judge
This consolidated case is scheduled for trial at a special session of the Court, to commence on April 25, 2022 in Washington, D.C. On February 24, 2022, respondent filed a Motion in Limine to Admit Certain Documents (Motion). On March 3, 2022, petitioners filed an Opposition to respondent's Motion. For the reasons discussed below, the admissibility of Exhibit 116-J and 135-R will be addressed at an appropriate point during the trial.
In the preamble of his Motion, respondent asks the Court to rule on an expedited basis and in advance of trial to "reduce the costs, additional witnesses, and trial time associated with responding to [petitioners'] objections during the trial." But upon review of respondent's Motion, it does not appear that respondent has quantified or identified the additional costs, witnesses, and trial time that will be purportedly required to address petitioners' objections.
In view of the foregoing, it is
ORDERED that respondent's Motion in Limine to Admit Certain Documents, filed February 24, 2022, is denied.