Opinion
15961-18 16273-18
09-20-2024
MICHAEL RAY MORENO, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
These cases were on the December 18, 2023 Los Angeles, California trial calendar, and were already by then the oldest ones on that calendar. We had thought they were finally headed to settlement, but then Ms. Cleveland died suddenly. We ordered respondent to report back on whether there had been any progress in substituting someone for Ms. Cleveland as a party in her case, any progress in transmitting respondent's administrative files in electronic form to Mr. Moreno, and the parties' views in the Moreno case on whether it makes sense to sever the cases if the parties in that case settle.
Respondent then reported that one of Ms. Cleveland's sisters was named in her will as executrix. She has now been named by a state court as executrix, and this summer respondent moved to substitute her as a party. Another part of the IRS has denied the late Ms. Cleveland's request for innocent-spouse relief.
It is time to see if these cases can finally be moved to settlement, and it is
ORDERED that on or December 19, 2024, the parties shall submit settlement documents or file a status report describing progress toward settlement or a narrowing of the issues to be tried.