Opinion
12164-20
04-01-2024
BARRY A. HALL & PHYLLIS J. HALL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This complex case was on the Court's March 6, 2023 trial calendar for Dallas, Texas. We had spoken with the parties in January to gauge progress and discuss a way forward and learned that there are very complicated carryback and carryforward losses.
The parties recently reported that they've settled the NOL carryback adjustment for 2014. Now the IRS has to formally post the carryback adjustment to petitioners' 2014 tax year. The parties believe that once applied to the 2014 tax year, the parties should be able to move toward a settlement of the 2015 tax year. This is good progress; the parties reasonably suggest reporting again in late spring if they haven't settled, and it is
ORDERED that on or before May 31, 2024 the parties shall submit settlement documents or file a status report describing their progress toward settlement or a narrowing of the facts to be tried.