Opinion
17147-21
04-14-2023
TRAVIS ANTHONY QUEEN & SUSAN QUEEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
This case was on the Court's October 24, 2022 trial calendar for Atlanta, Georgia. It's a case that's mostly about substantiation, and such cases can usually settle if the parties ask for and exchange information. There's been no settlement yet in this case, so we spoke with the parties today. We learned that Mr. Queen runs his business out of his home, and the remaining problem is proof of his utility expenses from five local utilities for one year - 2017. The source of the problem is he doesn't have records of his expenses himself and his effort to get them from the utilities has led to his learning that 4 of the 5 utilities he uses don't keep records for more than three years.
We discussed this in a phone call today, and Mr. Queen promised that he would send copies of the oldest bills that he can get from the 4 utilities that don't keep 2017 records to respondent's lawyer. He promised to include his check stubs for utility payments that he made in 2017. He promised to send his actual 2017 utility records from the one utility that did keep them. And he promised to do this on or before May 15, 2023. Respondent's lawyer promised to look them over and try to negotiate a reasonable settlement for these expenses, which tax law says can be estimated and don't need to be proven with precision.
It is therefore
ORDERED that on or before June 2, 2023 the parties shall file decision documents or respondent shall file a status report to describe the parties' progress toward settlement or a narrowing of the issues to be tried.