Opinion
15451-18
11-17-2021
Tin T. Vo Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Tamara W. Ashford, Judge
On November 10, 2021, pursuant to the Court's August 12, 2021, Order, respondent filed a Status Report, apprising the Court of the then present status of this case. Respondent reports that the Internal Revenue Service Revenue Agent assigned to review petitioner's 2014 Federal income tax return submitted on April 27, 2021, alerted him to discrepancies on that return. Respondent further reports that on August 17, 2021, he mailed petitioner a letter listing the concerns identified by the Revenue Agent and requesting explanations and substantiation for the identified items. According to respondent, on October 4, 2021, counsel for petitioner (who has not, as of the date of this order, entered an appearance in this case) responded via e-mail, stating that he requested records which are already within petitioner's possession and that petitioner will provide additional documentation.
Respondent also reports that on October 20, 2021, he e-mailed petitioner's counsel requesting that petitioner provide the requested information and substantiation by November 5, 2021; on the same day, he also e-mailed petitioner's counsel an encrypted Wage and Income Transcript for petitioner's 2014 taxable year. Finally, respondent reports that as of the filing of his November 10, 2021, Status Report, he has not heard back from petitioner's counsel, and that due to the severity of the discrepancies identified on petitioner's 2014 tax return, he has significant concerns that petitioner has substantially underreported his income and therefore anticipates that the parties will have to engage in formal discovery and subpoena third-party records. Respondent requests to file a Status Report within 60 days apprising the Court of the then present status of the case and to propose a comprehensive pretrial schedule. Upon due consideration, it is hereby
ORDERED that the parties shall, on or before January 17, 2022, file status reports, separately or jointly, apprising the Court of the then present status of this case.