Opinion
11427-21
03-25-2024
KARL A. JACOB, III & PATRICIA FAHEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This case was on the Court's May1, 2023 San Francisco, California trial calendar. We moved it to a status-report track because there is a very large amount of substantiation at issue and the parties thought it should be capable of settlement. Petitioners sent electronic copies of documentation to respondent in April, but then progress seemed to slow. More recently, however, respondent has reported that respondent received the results regarding the internal review and noticed they were incomplete as one thumb drive had been missed. That problem seems to have been solved, and it's still reasonable to think the case is headed to settlement rather than trial.
It is therefore
ORDERED that on or before April 29, 2024 the parties shall file a status report describing their progress toward settlement or a narrowing of the issues to be tried, including their respective estimates of a timeline to completion of settlement.