Opinion
2805-12
12-16-2021
Agnes M. Brady Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Cary Douglas Pugh Judge.
This case was continued from trial by order dated October 29, 2015, and the parties entered a Stipulation to be Bound by the Court's resolution of certain issues in Clay v. Commissioner, Dkt nos. 13104-11 and 7870-13. On April 24, 2019, we issued our opinion in Clay and on March 16, 2021, the Eleventh Circuit Court of Appeals affirmed. Clay v. Commissioner, 152 T.C. 223 (2019), aff'd, 990 F.3d 1296 (11th Cir. 2021). On October 12, 2021, the Supreme Court denied certiorari and our opinion and decision in Clay now are final. Pursuant to the parties' stipulation, therefore, the issue of the Federal tax treatment of the Quarterly Distributions and Christmas Bonuses (as those terms are defined in the stipulation) is resolved in favor of respondent.
On October 18, 2021, we directed the parties to file status reports advising of any issues remain for trial and outline the steps and timeline for preparing all remaining issues for trial or other resolution. On December 13, 2021, respondent filed a Status Report advising that respondent's counsel believes the parties have reached a basis for settlement. Upon due consideration and for cause, it is hereby
ORDERED that on or before January 17, 2022, the parties shall submit to the Court proposed stipulation documents or filed status reports regarding the then-present status of this case.