Opinion
12164-20
07-01-2024
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 petitioners have confirmed that the processing of the carryback has been assigned to a particular IRS employee. The parties request additional time to allow time for the IRS to apply the 2014 NOL carryback to the 2014 tax year, which, once applied, should allow the parties to compute a potential settlement for the 2015 tax year and resolve most or all the issues in this case. It is therefore
ORDERED that on or before July 26, 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.