Opinion
2207-18
06-30-2023
CONMAC INVESTMENTS INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
The Court issued a Memorandum Opinion in this case on March 27, 2023 (T.C. Memo. 2023-40), stating that a decision will be entered under Rule 155 of the Tax Court Rules of Practice and Procedure.
On June 28, 2023, docket entry 63, the parties filed a Joint Motion for Extension of Time requesting an extension of time of ninety (90) days to submit computations pursuant to Tax Court Rule 155. The Joint Motion indicates that the parties have been working together on draft computations and are in agreement about all but one adjustment in the computations. It also states that the unresolved adjustment relates to respondent's disallowance of a net operating loss carryback for tax year 2014 that resulted from petitioner's filing Form 1139, Corporation Application for Tentative Refund, for tax year 2018 in a subsequent year.
To facilitate continued discussions the parties have requested, and the Court will grant, an additional ninety (90) days to submit computations for entry of decision under Tax Court Rule 155.
After due consideration, and for cause, it is
ORDERED that, on or before October 2, 2023, the parties shall submit computations for entry of decision under Rule 155 of the Tax Court Rules of Practice and Procedure. If, however, the parties cannot file agreed computations, each party shall submit its proposed computation and decision document by the aforementioned date.