Opinion
14307-18L
05-05-2023
SCOTT ALLAN WEBBER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson Judge
This case is set for trial beginning at 9:00 a.m. on Tuesday, May 9, 2023. On May 4, 2023, petitioner filed a motion for a continuance, stating that he expects the Commissioner to make contentions at trial for which he has not had an opportunity to call witnesses and prepare for trial. We doubt that this is correct, but if petitioner is right, then that will be apparent at trial, and he could renew the request when his prediction has proved true. In the meantime, he should simply prepare to proceed at trial, at which he has the burden to prove that there is an available credit that the IRS failed to apply to his liability. It is
ORDERED that petitioner's motion for continuance is denied.