Opinion
13912-20
08-30-2022
FELIPE E. DOMINGUEZ & BERLIZA DOMINGUEZ, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Tamara W. Ashford Judge
On August 25, 2022, pursuant to the Court's May 5, 2022, Order, the parties filed a Joint Status Report, apprising the Court of the then present status of this case. The parties report that they have reached a basis for settlement in this case. The parties further report that the settlement resolves all issues in this case, as well as micro-captive insurance issues arising in non-docketed tax years that are not currently before the Tax Court; however, the terms of the settlement agreement require the parties to execute a closing agreement with respect to the non-docketed tax years before the parties are able to submit a decision document to the Court with respect to the docketed years. According to the parties, an Internal Revenue Service examination agent has been assigned to this case and is currently working with petitioners' counsel on the non-docketed tax years. Finally, the parties report that because of the complexity of the issues and numerous tax years involved, they anticipate that it will take several more months to finalize computations and submit a decision document in this case. The parties therefore request that the Court allow them to either submit a stipulated decision document or file another status report on or before November 30, 2022. Upon due consideration, it is hereby
ORDERED that the parties shall, on or before November 30, 2022, electronically submit to the Court an agreed stipulated decision document or file status reports, separately or jointly, apprising the Court of the then present status of this case.