Opinion
34676-21
09-18-2024
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 a notice of income-tax deficiency. A premature assessment on petitioner's account was found and respondent needed to do an abatement. He previously reported that he'd gotten the premature assessment abated, but in the course of doing so discovered another issue on petitioner's amended return.
Respondent recently reported that petitioner's counsel is in the process of providing returns for the 2018 tax year to clear up a minor discrepancy that should narrow the issues, and possibly, finally, resolve the case.
It is therefore
ORDERED that on or before November 6, 2024 the parties shall submit settlement documents or file a joint status report describing their progress.