Opinion
9179-19
02-02-2022
Amit Wadhwa & Sonali Jolly 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. It began as a case mostly about Schedule C substantiation, but has since been extended into questions of petitioners' entitlement to large deductions under sections 179D and 199. The Court put the case on a pretrial-order track, but on February 1, 2022 learned in a conference call that the parties have made good progress toward settling all issues but one -- petitioners' entitlement to a large section 179D credit. Respondent thinks he has a winning argument on that issue and wants to set it up for decision in a summary-judgment motion. The parties agree that it would make sense to take the case off the pretrial-order track while this motion is being briefed and under consideration. This is reasonable, and it is
ORDERED that the Court's September 21, 2021 order setting various pretrial deadlines is vacated. Instead, the Court will set up a briefing schedule for respondent's summary-judgment motion, and it is
ORDERED that respondent shall move for partial summary judgment on or before February 22, 2022; petitioners shall file a response on or before March 30, 2022; and respondent may file a reply on or before April 14, 2022. It is also
ORDERED that the parties may by stipulation filed with the Court change the deadlines for the briefing of the summary-judgment motion.