Roman v. Comm'r of Internal Revenue

Full title: LUMINITA ROMAN, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE…

Court: United States Tax Court

Date published: May 9, 2023

No. 10878-16 (U.S.T.C. May. 9, 2023)

Opinion

10878-16 7671-17

05-09-2023

LUMINITA ROMAN, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Emin Toro, Judge

ORDER

Emin Toro, Judge

On April 24, 2023, these cases were called, and trial was held before the undersigned judge in Los Angeles, California.

On April 13, 2023, the parties filed documents in Docket No. 10878-16 entitled Fourth Stipulation of Facts (Doc. 139), First Stipulation of Facts (Doc. 140), and Proposed Trial Exhibits (Doc. 141). On April 14, 2023, the parties filed in Docket No. 10878-16 documents entitled First Amendment to First Stipulation of Facts (Doc. 142), and Proposed Exhibits (Doc. 143 - 151). On April 18, 2023, the parties filed in Docket No. 10878-16 documents entitled Second Amendment to First Amendment to First Stipulation of Facts (Doc. 152) and First Amendment to Proposed Trial Exhibits (Doc. 153). On April 19, 2023, the parties filed in Docket No. 10878-16 documents entitled Second Stipulation of Facts and Third Stipulation of Facts (Docs. 154 & 155).

On April 13, 2023, the parties filed documents in Docket No. 7671-17 entitled Fourth Stipulation of Facts (Doc. 118), First Stipulation of Facts (Doc. 119), and Proposed Trial Exhibits (Doc. 120). On April 14, 2023, the parties filed in Docket No. 7671-17 documents entitled First Amendment to First Stipulation of Facts (Doc. 121), and Proposed Trial Exhibits (Doc. 122 - 130). On April 18, 2023, the parties filed in Docket No. 7671-17 documents entitled Second Amendment to First Amendment to First Stipulation of Facts (Doc. 131) and First Amendment to Proposed Trial Exhibits (Doc. 132). On April 19, 2023, the parties filed in Docket No. 7671-17 documents entitled Second Stipulation of Facts and Third Stipulation of Facts (Docs. 133 & 134).

Upon due consideration, in order to describe more accurately the materials filed with the Court and facilitate future reference to those materials, is it hereby

ORDERED that the parties' document entitled First Stipulation of Facts (Doc. 140 filed in Docket No. 10878-16 and Doc. 119 in Docket No. 7671-17) shall be recharacterized as the parties' First Stipulation of Facts Exhibits 1-J through 22-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 141 filed in Docket No. 10878-16 and Doc. 120 filed in Docket No. 7671-17) shall be recharacterized as the parties' First Stipulation of Facts Exhibits 23-R through 33-R. It is further

ORDERED that the parties' First Amendment to First Stipulation of Facts (Doc. 142 filed in Docket No. 10878-16 and Doc. 121 filed in Docket No. 7671-17) shall be recharacterized as the parties' First Amendment to First Stipulation of Facts [SOF 000001 through SOF001938]. It is further

ORDERED that the parties' Second Amendment to First Amendment to First Stipulation of Facts (Doc. 152 filed in Docket No. 10878-16 and Doc. 131 filed in Docket No. 7671-17) shall be recharacterized as the parties' Second Amendment to First Amendment to First Stipulation of Facts Exhibits 1-J through 33-R. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 143 in Docket No. 10878-16 and Doc. 122 in Docket No. 7671-17) is recharacterized as the parties' Second Stipulation of Facts Exhibits 34-P through 45-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 144 filed in Docket No. 10878-16 and Doc. 123 in Docket No. 7671-17) is recharacterized as the parties' Second Stipulation of Facts Exhibits 46-P through 58-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 145 filed in Docket No. 10878-16 and Doc. No. 125 in Docket No. 7671-17) is recharacterized as the parties' Second Stipulation of Facts Exhibits 59-P through 62-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 146 filed in Docket No. 10878-16 and Doc. No. 124 in Docket No. 7671-17) is recharacterized as the parties' Second Stipulation of Facts Exhibits 63-P through 76-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 147 filed in Docket No. 10878-16 and Doc. No. 126 in Docket No. 7671-17) is recharacterized as the parties' Second Stipulation of Facts Exhibits 77-P through 97-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 148 in Docket No. 10878-16 and Doc. 127 in Docket No. 7671-17) is recharacterized as the parties' Second Stipulation of Facts Exhibits 98-P through 103-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 149 filed in Docket No. 10878-16 and Doc. 128 in Docket No. 7671-17) is recharacterized as the parties' Second Stipulation of Facts Exhibits 104-P through 105-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 150 filed in Docket No. 10878-16 and Doc. No. 129 in Docket No. 7671-17) is recharacterized as the parties' Second Stipulation of Facts Exhibits 106-P through 110-P. It is further

ORDERED that the parties' Proposed Trial Exhibits (Doc. 151 filed in Docket No. 10878-16 and Doc. 130 filed in Docket No. 7671-17) is recharacterized as the parties' Third Stipulation of Facts Exhibits 111-P through 147-R. It is further

ODERED that the parties' First Amendment to Proposed Trial Exhibits (Doc. 153 filed in Docket No. 10878-16 and Doc. 132 filed in Docket No. 7671-17) is recharacterized as the parties' First Amendment to Third Stipulation of Facts Exhibits 111-P through 147-R. It is further

ORDERED that the parties' Fourth Stipulation of Facts (Doc. 139 filed in Docket No. 10878-16 and Doc. 118 in Docket No. 7671-17) is recharacterized as the parties' Fourth Stipulation of Facts Exhibit 148-J.