Opinion
20038-12
10-18-2021
Mary Kelly Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Cary Douglas Pugh, Judge
This case was continued from trial by order dated October 29, 2015, and the parties entered a Stipulation to be Bound by the Court's resolution of certain issues in Clay v. Commissioner, Dkt nos. 13104-11 and 7870-13. On April 24, 2019, we issued our opinion in Clay and on March 16, 2021, the Eleventh Circuit Court of Appeals affirmed. Clay v. Commissioner, 152 T.C. 223 (2019), aff'd, 990 F.3d 1296 (11th Cir. 2021). On October 12, 2021, the Supreme Court denied certiorari and our opinion and decision in Clay now are final. Pursuant to the parties' stipulation, therefore, the issue of the Federal tax treatment of the Quarterly Distributions and Christmas Bonuses (as those terms are defined in the stipulation) is resolved in favor of respondent. Upon due consideration, and for cause, it is hereby
ORDERED that on or before December 15, 2021, the parties shall file status reports that state whether any issues remain for trial and outline the steps and timeline for preparing all remaining issues for trial or other resolution.