Wills v. Comm'r of Internal Revenue, 9940-22S

CourtUnited States Tax Court
Writing for the CourtPugh Judge
Docket Number9940-22S
Decision Date01 July 2022



No. 9940-22S

United States Tax Court

July 1, 2022

This case is set for trial at the Washington, District of Columbia trial session beginning at 10:00 am on Monday, October 31, 2022.

Please refer to the Notice Setting Case for Trial for more information.


Pugh Judge

Read this Order because it sets out the Court's standing procedures for the trial session. It explains actions you are required to take (ordered) and important information you need to pay attention to. If this is your first time appearing before the U.S. Tax Court, please pay special attention to the attached "Petitioner's (Taxpayer's) Getting Ready for Trial Checklist".

The parties are ORDERED to (1) participate in pre-trial matters, including conference calls and pretrial conferences scheduled by the Judge, and (2) attend the trial. If you do not follow this Order, the Judge may dismiss your case and enter a Decision against you.

Important information you need to pay attention to:

1. About the Court. The U.S. Tax Court hears disputes between taxpayers (petitioners) and the IRS (respondent). The Court is independent of, and not affiliated with, the IRS. Documents previously given to the IRS are not part of the record in this case and may not be considered unless made part of this case.

2. Contact Information. The parties must provide the Court with current contact information. If your phone number, email, or mailing address changes, inform the Court right away by filing a Notice of Change of Address form, available on the Court's website, www.ustaxcourt.gov.

3. Electronic Filing (eFiling). The Court encourages registration for DAWSON, the Court's electronic filing and case management system, so that you can electronically file and view documents in your case. If you are not registered for eFiling, you must send the opposing party a copy of any document you file with the Court. To register for DAWSON, email dawson.support@ustaxcourt.gov. eFiling will remain available to parties during the trial session. For more information, see www.ustaxcourt.gov.


4. Communication Between the Parties. The parties must begin discussing settlement and/or preparation of a stipulation of facts (facts on which the parties agree) as soon as possible. All minor issues should be settled so that the Judge can focus on the issue(s) needing a decision. Some cases may be susceptible to partial or full settlement, and the Court expects the parties to negotiate in good faith with this goal in mind. If a party has trouble communicating with another party or complying with this Order, that party should tell the Judge right away by filing a Status Report or requesting a conference call by calling the Judge's chambers at the phone number listed below.

5. Language Barriers. All Court proceedings are conducted in English. All documents must be filed in English or include a certified English translation. You should let the Judge know as early as possible if you require help with English. It is generally the responsibility of each petitioner to bring an interpreter. If you give advance notice, the Court may have one available.

6. Readiness for Trial and Participation. If your case needs a trial, the parties must be ready for trial when scheduled by the Judge. If you need special help with scheduling your trial, call the Judge's chambers (at the telephone number listed below) as early as possible and before the first day of the trial session. If you have not yet settled your case and you do not participate in conference calls and pretrial conferences, or appear at trial, the Judge may dismiss your case and enter a decision against you. The Judge may also dismiss your case and enter a decision against you if you do not follow this or other Court Orders.

7. Relevant Deadlines. The Court has adopted the deadlines outlined...

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