Opinion
10602-22
05-30-2023
GAETANO PATRINOSTRO, Petitioner 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. It's based on a notice of deficiency that the IRS sent to the owner of a restaurant in Sonoma County. The notice was based on a substitute for return that the IRS prepared when petitioner didn't file one himself for 2015. These substitutes for returns usually show a lot of income, but not many deductions. It would be a very unusual restaurant that didn't have quite a few deductible business expenses.
Mr. Patrinostro has been in regular contact with Respondent. He has also given his CPA a power of attorney to discuss his tax problem with the IRS. Petitioner has provided documents to his CPA, however his CPA was out of the office until this month. It is therefore
ORDERED that on or before June 21, 2023 respondent shall file a status report describing progress in contacting Mr. Patrinostro's CPA and outlining a schedule for review of those records and moving this case closer to settlement.