Opinion
20361-22L
09-20-2024
JOHN COMPAGNO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's May 1, 2023 San Francisco, California trial calendar. It is a somewhat unusual collection-due-process case, in that petitioner doesn't contest his liability, but reasonably expects to fully pay it with the sale of a winery in Oregon. Marketing this type of property, however, requires the retention of a broker who specializes in the field. Respondent agrees that it would be most efficient, especially in what seems to be a difficult time for real-estate sales, to let petitioner have enough time to market this property to maximize its price.
The parties recently reported that petitioner has a broker who continues to market the winery and both agree that with additional time petitioner will be able to sell the winery and fully pay his liability. It is therefore
ORDERED that on or before March 14, 2025 the parties file a status report describing their progress toward mooting this case through the winery's sale.