Opinion
36381-21L
08-28-2023
BRENDA L. BENSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
This case was on the Court's September 12, 2022 San Francisco, California trial calendar. When we spoke with the parties we urged them to reach an agreement on the contents of the administrative record in this case. Respondent reported in April that he has sent a copy of the administrative file to petitioner's counsel, and would expect to move for summary judgment. Respondent recently reported that he still needs more time to file the motion. The Court expects that this will be the last request for more time, and it is
ORDERED that on or before October 20, 2023 the parties shall submit settlement documents or respondent shall file a motion for summary judgment or a status report describing their progress in setting up the case for decision by submission under Rule 122.