Opinion
4998-23L
07-12-2024
KAROLYN BERKMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
This unusual collection-due-process case was on the February 12, 2024 Los Angeles, California trial calendar. We spoke with the parties last year 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 recently reported that he's mailed proposed decision documents to petitioner that would resolve the case in her favor. He reasonably asks for another month to execute and file them. It is therefore
ORDERED that on or before August 8, 2024 the parties submit settlement documents or respondent files a status report on their progress.