Opinion
3033-19
08-30-2023
JAVID YADEGAR & MAHNAZ YADEGAR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge.
This case was on the Court's October 19, 2020 trial calendar for New York City. It'd been continued once before because of its similarity to an even older case, Soleimani v. Commissioner, dkt. no. 8884-13. Petitioners moved to continue this case until Soleimani was decided, which was reasonable because there seemed to be a high probability that the result in Soleimani would lead to a settlement of this case. The Court then released its opinion in Soleimani, and it now seems likely that the result in that case was too dependent on its idiosyncratic facts to easily lead to progress in this case. Dr. Yadegar's lawyer then withdrew, which means we have a four-year-old case about tax years that stretch back to 2007 and in which there has been little progress.
We spoke with the parties today, and all agreed it made sense to begin informal discovery. Respondent promised to send a Branerton letter in which the IRS will describe the records that it wants from Dr. Yadegar. The IRS lawyer also promised to review the 1 and 1/2 boxes of records in the government's own administrative file to get a working knowledge of the case from them. Dr. Yadegar for his part promised to gather his documents from his former lawyers and be willing to talk with the IRS's lawyer.
The Court will check in with the parties in the fall to see that the case is making progress. To do so, it is
ORDERED that respondent file a status report on or before October 10, 2023 in which he describes any progress in informal discovery.