Opinion
14785-20
08-29-2022
JASON D. WALL & CHARLENE REICHLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This case was on the Court's April 4, 2022 trial calendar for Los Angeles, California. We continued it to allow the parties to cooperate in informal discovery and negotiation at IRS Appeals. The parties recently reported petitioners sent extensive documentation to the Appeals Office, which has still not even looked at any of it. This is suboptimal, because the case is almost entirely about substantiation, but the Court understands that respondent's counsel has limited power to get IRS Appeals to work on the case. It is therefore
ORDERED that on or before October 25, 2022 the parties submit settlement documents or file a joint status report describing any progress towards settlement.
The parties should be aware that the Court is considering adding this case to its January 2023 Los Angeles calendar.