Opinion
3147-21L
03-04-2022
Duane Whittaker & Candace Whittaker Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Mark V. Holmes Judge
This case is on the March 21, 2022 St. Paul, Minnesota trial calendar. In it petitioners seek review of respondent's notice of determination. They have agreed to the contents of the administrative record and want it decided under Rule 122. The Court somewhat confusingly filed this single request as two motions, so it is
ORDERED that the parties' motion for leave to file motion to submit case pursuant to Rule 122 is granted. It is also
ORDERED that the parties' motion to submit case pursuant to Rule 122 is granted. It is also (in keeping with this division of the Court's strong preference for serial briefing)
ORDERED that the schedule for posttrial briefing is:
petitioners' opening brief is due on or before May 4, 2022; respondent's answering brief is due on or before June 6, 2022; and petitioners' reply brief on or before June 21, 2022.
The parties' briefs should not include detailed findings of facts. Instead they should state the facts in narrative form with citations to the record. It is also
ORDERED that the parties may be written stipulation filed with the Court change this briefing schedule 1