- 7 - deductions, additions to tax under section 6651(a), and accuracy-related penalties under section 6662(a). The Court calendared the resulting case for trial on the Court’s regular 2- week session in San Diego, California, commencing on October 20, 2003 (regular San Diego session), and notified the parties of this action on May 22, 2003. Montgomery did not prepare to try petitioners’ case at the regular San Diego session but assured Ms. Keil that he would cause the case to be continued until the spring of 2004. Early in October 2003, Ms. Keil called Montgomery to ask him about the scheduled trial, and she inquired into whether he was going to prepare petitioners for it. He reiterated that he was going to have the case continued, and he asked Ms. Keil to give him a good reason to continue the case. He added that the case was not ready to be tried during the regular San Diego session. Pursuant to Montgomery’s request, petitioners presented him with a two-sentence letter from a medical doctor stating that “I am treating Mr. Keil for an episode of Major Depression. He is being treated with an antidepressant, Paxil, and cognitive psychotherapy”. Montgomery attached this letter to a motion for continuance. In relevant part, he asserted in that motion that Mr. Keil was suffering from depression and that Mr. Keil was critical to petitioners’ case because he was more actively involved with the business’s income and expenses than was Ms.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011