Opinion
10602-22 10721-22
12-26-2023
GAETANO PATRINOSTRO, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
The lower-numbered 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 for his 2015 tax year. We learned earlier this year that the IRS had audited the Patrinostros for their 2016 tax year for similar reasons. We consolidated and moved them to a status-report track for now. Respondent recently reported that the two missing returns have been completed according to petitioner, but they have not yet been submitted or checked by the IRS. That's good enough progress for now, however, and it is
ORDERED that on or before February 22, 2024 respondent shall file a status report describing progress in completing discovery and moving these cases to settlement.