Opinion
4998-23L
12-28-2023
KAROLYN BERKMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This unusual collection-due-process case is on the February 12, 2024 Los Angeles, California trial calendar. We spoke with the parties on November 14, 2023 and learned that it may well have its origins in Ms. Berkman's former husband's transfer of a partnership interest more than 15 years ago. This transfer was at best sloppily done; at worst it may have been part of a long-ago scheme to transfer the benefits away from Ms. Berkman while leaving her with a very heavy tax burden.
Respondent's counsel promised to contact the partnership's accountant to see what he can discover. But this case might be heading in the direction of a challenge to Ms. Berkman's liability or possibly her entitlement to innocent-spouse relief. Respondent promised to tell Ms. Berkman and the Court what he is able to discover in a status report due January 16.
The Court apologizes to Ms. Berkman for not sending this order out earlier, thus causing her unnecessary anxiety, but it is now
ORDERED that on or before January 16, 2024 respondent file a status report on his trying to informally understand the issues in this case by contacting the partnership involved, and also to make any suggestions about how to resolve it.