Opinion
14740-19
01-16-2024
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, however, that the settlement broke down. Respondent needs time to obtain and review the administrative file and to review the substantiation documents provided by petitioner for a potential resolution without a trial or for trial preparation. If the parties do not reach a settlement soon, this case seems headed for a pretrial-order track, perhaps one accelerated to get it ready for trial in April.
It is therefore
ORDERED that on or before February 9, 2024 the parties shall submit decision documents or file a joint status report describing their progress.