Opinion
14740-19
08-31-2023
NOELLE M. ALESSANDRA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This substantiation case was on the Court's June 12, 2023 Buffalo, New York trial calendar. It'd been continued twice before, so we continued it a third time only on the parties' representation that they'd reached a basis for settlement at IRS Appeals. They recently reported, however, that the settlement broke down. We spoke with them today and learned that not all hope of a compromise is forlorn. Petitioner promised to give copies of the substantiation she'd already sent to IRS Appeals to respondent's counsel; respondent promised to look at it and speak with petitioner's counsel within a month after that. The Court suggested that it will put the case on a strict pretrial order if settlement is not achieved.
It is therefore
ORDERED that on or before October 11, 2023 the parties shall submit decision documents or file a joint status report describing their progress.