Opinion
5691-23L
04-03-2024
VLADIMIR KAYE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This collection-due-process case was on the December 18, 2023 Los Angeles, California trial calendar. Respondent moved without objection for a continuance. Petitioner may be seeking anything from a remand to a collection alternative to a challenge to his underlying liability. Respondent is willing to try to solve the case holistically by discussing all these possible outcomes so as to liberate it from the formal constraints and limitations of judicial review. Petitioner stated that he's willing to try as well. This would avoid problems with the scope of review and lengthy delays that remand would likely cause if that was where the case headed.
Respondent recently reported that the parties have made good progress in informal discovery but do need some more time to obtain and review additional information and documents which could lead to resolution of some or all of the issues in this case. This is reasonable and it is therefore
ORDERED that on or before June 10, 2024 the parties submit decision documents or file a joint status report describing their progress in exchanging documents and moving toward settlement.