Opinion
20840-17
01-03-2023
RICHARD J. O'NEILL TRUST, ANTHONY R. MOISO, TRUSTEE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Upon due consideration and for cause more fully appearing in the Court's Memorandum Opinion, T.C. Memo 2022-108, it is
ORDERED that petitioner's motion for partial summary judgment, filed October 22, 2018, is denied. It is further
ORDERED that respondent's motion for partial summary judgment, as supplemented December 21, 2018, is granted. It is further
ORDERED that the parties shall, on or before January 19, 2023, file a joint report detailing the then-present status of this case.