Opinion
11004-21L
11-28-2022
ESSENTION GROUP INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
This case was on the Court's September 12, 2022 trial calendar for San Francisco, California. We continued it at the parties' request to allow them time to try to solve it through action on petitioner's long-pending request for audit reconsideration. If the IRS grants that, a settlement would be highly likely; if not, the case can move toward resolution on the basis of the administrative record. The parties recently reported that respondent has found the relevant IRS files and counsel is coordinating consideration with the agent who's handling the audit reconsideration. The case can stay on a status-report track, and it is
ORDERED that on or before January 6, 2023 the parties shall file a joint status report describing their progress in considering petitioner's request for audit reconsideration and any important developments.