Opinion
34676-21
07-15-2024
JOSEFINA A. MANALO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES JUDGE.
This case was on the Court's September 12, 2022 San Francisco, California trial calendar. The parties reported last year that petitioner had filed amended gift-tax returns for the transactions that had triggered the notice of income-tax deficiency. A premature assessment on petitioner's account was found and respondent needed to do an abatement. He recently reported that he's gotten the premature assessment abated, but in the course of doing so discovered another issue on petitioner's amended return. The parties remain confident that they can settle, and reasonably ask to report again at the end of summer if they haven't.
It is therefore
ORDERED that on or before September 4, 2024 the parties shall submit settlement documents or file a joint status report describing their progress.