Opinion
20317-19
09-24-2024
BHUPINDER S. UPPAL & RAVINDAR K. UPPAL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's October 25, 2021 trial calendar for San Francisco, California. The case was one of a consolidated group that had a massive number of substantiation issues that all parties agreed they would work on cooperatively to try to at least narrow whatever had to be tried. By the beginning of this summer this case remained unsettled, but a check of the docket didn't show any progress in settling.
We therefore spoke with the parties today. It turns out the lack of new docket entries in this case didn't mean the parties weren't working on it. Settlement of this case depends on resolution of a basis issue. Respondent said he expects to have computations reflecting two different approaches to basis completed and ready to send to petitioners in the next week or so. Petitioners reasonably ask for two months to look them over. Both parties expect to either settle the case by then, or be closer to being prepared to conclude they're at an impasse and need to move to a pretrial track.
It is therefore
ORDERED that on or before November 25, 2024 the parties submit settlement documents or file a status report describing their progress toward settlement or a narrowing of the issues to be tried.