Opinion
8242-21S
07-01-2022
JOHN DANIEL GOULA & ASHLIE CARTER GOULA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph W. Nega, Judge
This case was calendared for remote trial at the session of the Court scheduled to commence on May 23, 2022, for cases in which Buffalo, New York was listed as the place of trial. On April 28, 2022, respondent filed a Status Report indicating therein that the parties have reached a basis of settlement in this case. Pursuant to the Court's Order issued May 10, 2022, this case was stricken for trial from the May 23, 2022, Buffalo, New York, session and continued. On June 28, 2022, the parties filed a Settlement Stipulation and a Proposed Stipulated Decision, which were signed by all parties.
Upon further review of the record in this case, it appears that the Petition may have been filed untimely.
In view of the foregoing, it is
ORDERED that, on or before August 1, 2022, the parties shall file a joint response (or separate responses if a joint response is not possible) to this Order addressing whether the Petition in this case was timely filed.