Opinion
3965-20
10-26-2022
JAMES J. MAGGARD & SZU-YII CHANG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's October 25, 2021 trial calendar for San Francisco, California. The two major issues are substantiation of business expenses and the possibility that the business might have lost its status as an S corporation due to disproportionate distributions. Progress toward settlement seems to have slowed, but the parties recently promised they would by November 4 finish a stipulation that would enable them to submit the case for decision under Rule 122. The Court will therefore let it be
ORDERED that on or before November 14, 2022 the parties file a status report to describe their progress in settling the case or moving to submit the S corporation issue for decision under Rule 122.