Opinion
6209-20
06-27-2024
YOSEPH JENAYE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge.
This case is one of about twenty similar cases involving the effect of a closing agreement on the availability of the foreign earned income exclusion for income earned in Australia. On September 2, 2023, petitioner filed a Motion for Partial Summary Judgment (MPSJ). By Order served September 7, 2023, the Court ordered the MPSJ be held in abeyance pending further developments in the other similar cases. On June 27, 2024, the parties filed a Proposed Stipulated Decision that resolves all issues in this case.
Upon due consideration, it is
ORDERED that petitioner's MPSJ, filed September 2, 2023, is denied as moot. A decision in this case will be entered in due course.