Opinion
12982-20
03-30-2022
ORDER
Emin Toro Judge
This case is currently calendared for trial during the Court's April 4, 2022, San Francisco, California, trial session. On March 29, 2022, the Court held a conference call with the parties to discuss the status of the case and preparations for trial. Following those discussions and in light of petitioner's desire to consult with representatives from low-income taxpayer clinics, the Court concluded that the parties should be present at the April 4, 2022, calendar call to permit such consultation and potentially narrow the issues for trial. The Court also indicated to the parties that, if the case proceeds to trial, the Court anticipates the trial will take place at 2:00 p.m. Pacific Time on Monday, April 4, 2022.
Finally, the Court believes that a pretrial conference may facilitate a more efficient trial. Therefore, if the case remains for trial, the Court expects to schedule a pretrial conference with the parties after the calendar call and before the beginning of the trial. The parties should be prepared to address at the pretrial conference any evidentiary issues relating to the application of I.R.C. § 6015(e)(7).
Upon due consideration, it is hereby
ORDERED that the parties shall attend the Court's April 4, 2022, San Francisco, California, calendar call scheduled for 10:00 a.m. Pacific Time, and shall be prepared to proceed as outlined above.