Opinion
15075-20 15036-21
07-12-2022
Annalie Frutos, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
These cases were on the Court's April 4, 2022 trial calendar for Los Angeles, California, but we continued them to give the parties a chance to complete some discovery and then try to settle.
A key third party has produced the records it had. They were voluminous enough to make the Commissioner put a revenue agent on the cases. Respondent recently reported that the revenue agent has now completed her review, but asked petitioner for some more documents. When petitioner said he lacked any more, respondent submitted a Form 8796, Request for Return/Information, to the California Department of Tax and Fee Administration, via the Federal/State Tax Exchange program, to help find the missing documentation. This help to a taxpayer is to be appreciated, and any documents it uncovers will likely help settle the case. It is therefore
ORDERED that on or before October 14, 2022 the parties shall submit settlement documents or respondent shall file a status report describing progress toward settlement or a narrowing of the issues to be tried.