Opinion
906-21
07-12-2022
ESTATE OF JEAN L. WALSH, DECEASED, DONOR, ROBERT J. TRAVER, EXECUTOR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's April 4, 2022 trial calendar for Los Angeles, California. The case involves two split-dollar life-insurance transactions that had both gift- and estate-tax consequences. The parties understandably wanted to discuss settlement at IRS Appeals; doing so may narrow a particularly complicated case. The parties recently reported that the case is pending with the Office of Appeals and petitioner's counsel is working diligently with the assigned Appeals Officer to resolve this case without trial. The parties hope that they will be able to come to an agreement or, in the alternative, determine that the case should be released by the Office of Appeals for trial preparation by the end of this year. It is therefore
ORDERED that on or before December 16, 2022 the parties shall file a status report to describe their progress toward settlement at IRS Appeals.