Sergile v. Comm'r of Internal Revenue

Full title: DANIEL FRANCIS SERGILE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court: United States Tax Court

Date published: Mar 25, 2022

No. 7852-19 (U.S.T.C. Mar. 25, 2022)

Opinion

7852-19

03-25-2022

DANIEL FRANCIS SERGILE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Albert G. Lauber Judge

ORDER

Albert G. Lauber Judge

On June 10, 2021, respondent filed a status report representing that the parties had reached a basis for settlement but that petitioner had not yet returned executed decision documents. On June 14, 2021, we ordered the parties to submit decision documents or file a joint status report by July 27, 2021. We did not receive any communication from the parties by that date, so we directed them to submit decision documents or file a status report by September 20, 2021.

On September 10, 2021, respondent filed a status report representing that the parties were preparing tax computations based on their agreement and that they would submit decision documents in due course. On November 5, 2021, respondent filed another status report. In that report respondent's counsel represented that she had spoken with petitioner and that he indicated that he would return executed decision documents soon. We accordingly ordered the parties to submit decision documents or file another status report by December 23, 2021.

On December 21, 2021, respondent filed a status report representing that petitioner is refusing to sign the decision documents. By Order served December 22, 2021, we advised the parties that if they did not submit decision documents by January 24, 2022, we would set this case for trial. The parties did not submit decision documents by that date, and on March 22, 2022, respondent filed a status report representing that he does not believe that the parties will resolve the case.

In consideration of the foregoing, it is

ORDERED that this case is calendared for trial during the Court's June 13, 2022, remote trial session. The undersigned will be presiding. It is further

ORDERED that the Clerk of the Court shall serve on the parties: (1) a Notice of Remote Proceeding that shall contain comprehensive instructions on how to participate in the Court's June 13, 2022, trial session, and (2) a copy of the Standing Pretrial Order for that trial session.