Opinion
13791-21 15480-21
11-28-2022
Mario Ramirez & Leticia Ramirez, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
The higher-numbered case was on the Court's September 12, 2021 San Francisco, California trial calendar. Both it and the lower-numbered case arise from the same company's tax troubles. Those troubles are mostly questions of substantiation, and we continued the cases to enable them to try to settle at IRS Appeals. Respondent recently reported that informal discovery seems to have broken down. If so, the Court will move these cases to a pretrial-order track with firm deadlines, but will give the parties another chance to get these cases moving before it does so. It is therefore
ORDERED that on or before January 13, 2023 respondent shall file a status report describing their progress in settling the case at IRS Appeals, including a summary of any conference between the parties and any progress in informal discovery.