Opinion
21596-19L
01-11-2022
Moses Shang & Catherine T. Shang Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Joseph Robert Goeke Judge
Pending before the Court is petitioners' Motion to Preclude, filed August 13, 2021, as supplemented on August 13, 2021, and respondent's Motion for Summary Judgment, filed August 18, 2021, as supplemented on November 26, 2021. Given the parties' positions, we do not believe this case is appropriate for summary judgment. The Court will deny respondent's pending motion. Accordingly, it is
ORDERED that this case is calendared for trial on the Court's Chicago, Illinois Special Session commencing on August 8, 2022, at a time and date certain of 4:00 p.m., on Tuesday, August 16, 2022, in Room 3908, 39th Floor, Kluczynski Federal Building, 230 S. Dearborn Street, Chicago, Illinois 60604. It is further
ORDERED that petitioners' Motion to Preclude, as supplemented, is taken under advisement and a hearing on the motion will be held during the above-referenced time and date certain. It is further
ORDERED that respondent's Motion for Summary Judgment, as supplemented, is denied without prejudice. It is further
ORDERED that the petitioners are directed on or before March 7, 2022, to file with the Court a detailed statement as to the basis of their position challenging the underlying liability. Petitioners should specifically state why the assessed amount is incorrect. It is further
ORDERED that the petitioners are directed on or before May 6, 2022, to provide to respondent all of the documents that they have that support their position relative to the underlying liability. It is further
ORDERED that the Clerk of the Court is directed to attach to this Order a copy of the Standing Pretrial Order for the above-referenced session.
This Order constitutes official notice of the same to the parties herein.