JOINT MOTION FOR A SECOND SIXTY-DAY EXTENSION FOR RESPONSE TO PETITION

SECOND REQUEST

LR IA 6-1, 6-2 and 7-1

NANCY J. KOPPE, District Judge.

COMES now Petitioner Veg. Corp., Inc. and Respondent United States of America, by and through their undersigned counsel, and submit a Second Joint Motion to extend the time in which the United States has to respond to the Petition for an additional period of sixty (60) days up until May 22, 2018. This extra time period is sought because after the filing of the prior Joint Motion, Petitioner located and produced to the IRS a substantial quantity of additional documentation or records which are currently being reviewed by the IRS examination agents:

1. On November 17, 2017, Veg Corp., Inc. ("Veg Corp.") filed its Petition to quash a Formal Document Request issued by the Internal Revenue Service ("IRS") to Petitioner with respect to foreign-based documentation in accordance with 26 U.S.C. (IRC) § 982(c)(2).

2. The IRS is conducting an audit examination of Veg Corp.'s corporate income tax return for the year 2013. In connection with the examination, the IRS issued several Information Document Requests ("IDR") to Veg Corp.

3. On August 21, 2017, the IRS issued a Formal Document Request to Veg Corp. under IRC § 982 in which it contended that Veg Corp.'s responses to the IDRs were insufficient or incomplete. On November 15, 2017, the IRS granted Veg Corp an extension until December 15, 2017 in which to respond to the Formal Document Request.

4. Veg Corp. thereafter filed this Petition to quash the Formal Document Request in accordance with IRC § 982(c)(2) for the reasons stated in its Petition.

5. Following service of process of the Petition on the United States, the parties filed a (First) Joint Motion to provide the United States with a sixty-day extension up to March 23, 2018 in which to respond to the Petition (ECF No. 9). On December 22, 2017, the Joint Motion was granted by the Court (ECF No. 10).

6. On January 2, 2018, Petitioner submitted to the IRS thousands of additional newly discovered documents regarding its business activities for the periods under audit. These records were apparently discovered after the filing of this proceeding. The documents were originally produced in a format which was not easily accessible by the IRS exam team. On February 27, 2018, the Petitioner sent the records to the IRS in another electronic format. These records are now currently under review by the IRS exam team. The additional time sought herein will also provide more time for the parties to further discuss narrowing or clarifying the issues involved herein.

7. The parties therefore seek a second sixty-day extension up until May 22, 2018 in which the United States has to respond to the Petition.

IT IS SO ORDERED.