In Uncategorized on 11/10/2022 at 14:45

Judge Alina I. (“AIM”) Marshall devotes ten (count ’em, ten) pages of her order in Janice A. Wieslander, Docket No. 18546-19, filed 11/10/22, to a comprehensive pretrial outline, establishing a well-marked pathway to resolution of Janice’s furniture business and horsing around. Judge AIM has devoted great insight and energy to keep both IRS and Janice on the straight-and-narrow.

Here’s an example.

The parties shall “(2) explain their views on the following deductions with respect to petitioner’s horse activity for the taxable year 2010:

(a) schedule C legal and professional services,

(b) schedule C travel,

(c) schedule C utilities;

(d) schedule C meals and entertainment;

(e) schedule C rent/lease – otherbusiness property;

(f) schedule C supplies;

(g) schedule C car and truck expenses;

(h) schedule C office expense;

(i) any other items the party believes to be at issue with respect to the horse activity for taxable year 2010. The parties shall include the following items:

i. the amount reported in petitioner’s return;

ii. the amount of the adjustment made in the notice of deficiency upon which this case is based;

iii. the amount, if any, conceded by either party;

iv. each party’s views as to whether they have the burden of proof with respect to part or all of the item;

v. the legal theories upon which the party intends to proceed with respect to the issue;

vi. specific items of substantiation or other evidence that the party intends to offer at trial to support this item (including number of pages for documents).” Order, at pp. 2-3.

And in case the parties get discursive or otherwise wander from the path, “(T)he parties shall label each item pursuant to the numbering system used herein (e.g., when addressing the deduction for schedule C legal and professional service expenses related to taxable year 2010 for the horse activity reported on petitioner’s return, the heading of the section shall be marked (2)(a)(i)).” Order, at p. 3.

I’ve known 20-year drill sergeants who were less precise.


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