Opinion
23373-18
11-10-2021
Peak Potentials Training International Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
David Gustafson, Judge.
On October 18, 2021, petitioner filed a "Motion for International Judicial Assistance" (Doc. 51). Our order of October 22, 2021 (Doc. 54), ordered the Commissioner to file a response by November 8, 2021, and ordered petitioner to file a reply by November 30, 2021. The Commissioner filed his response (Doc. 55) on November 5, 2021, stating objections; but in that response he suggested several revisions petitioner could make that would enable the Commissioner to withdraw his objections. A cursory reading of the response makes it seem likely that the objections can indeed be eliminated or at least reduced. It is therefore
ORDERED that, before filing its reply due November 30, 2021, counsel for petitioner shall initiate a telephone conference with counsel for respondent, with a view toward resolving their differences in whole or in part. The reply shall explain the extent, if any, to which petitioner is willing to make adjustments and the extent, if any, to which the parties are able to agree. If the current deadline for petitioner's reply does not leave sufficient time to engage in this consultation, then petitioner should file a motion for an extension.