Opinion
8357-23L 8358-23L
09-25-2024
GOLDEN HARVESTS LLC, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge.
These consolidated cases are set for trial at the Court's December 16, 2024, Denver, Colorado trial session. On September 20, 2024, the parties filed a Joint Motion for Continuance of trial seeking to have these cases restored to the general docket. The parties previously requested a continuance of trial of these matters, by motion on November 16, 2023, wherein they previously stated that "they determined that it was not logistically feasible for respondent's counsel to review, organize, and incorporate the newly discovered documents into his then-existing versions of the Administrative Records in the cases such that it would allow Petitioner's counsel adequate time to review them for purposes of stipulation by November 24, 2023."
The Court granted the parties prior Joint Motion for Continuance, but now some 10 months later the parties seek another continuance largely based on the same grounds. While the Court is sensitive to the parties' request for more time, there appears to be little progress made toward stipulation of the Administrative Records which were due on August 31, 2024.
Considering the foregoing, and finding that the parties have failed to establish exceptional circumstances under Tax Court Rule 133, it is
ORDERED that the parties' Joint Motion for Continuance filed on September 20, 2024, is denied without prejudice. It is further
ORDERED that on or before October 10, 2024, respondent shall file the Administrative Records in these cases pursuant to Rule 93(a).