Opinion
11427-21
04-12-2023
KARL A. JACOB, III & PATRICIA FAHEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's May 1, 2023 San Francisco, California trial calendar. We moved it to a status-report track because there is a very large amount of substantiation at issue and the parties thought it should be capable of settlement. We made the first report due this month because IRS Appeals had seemingly not been working on it. But now the parties report that things are back on the settlement track inasmuch as Appeals is ready to receive petitoners' documentation and forward it on to Exam. This is a positive development, but also one that points to a long time till the case is finally settled or tried. The parties reasonably suggest reporting again this summer, and it is
ORDERED that on or before July 7, 2023 the parties shall file a status report describing their progress toward settlement or a narrowing of the issues to be tried.