Opinion
4611-18 19297-18 2424-19 7558-19
07-12-2024
MARC DOUGLAS MURR, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
These cases were on the Court's March 6, 2023 trial calendar for Dallas, Texas. The parties had a final exchange of IRS documents that respondent produced through informal discovery and FOIA responses. The last tranche was apparently quite heavily redacted, which slowed things down as the parties worked through them to try to settle.
The parties recently reported they have discussed the proposed adjustments at issue. The proposed adjustments, including adjustments with respect to individual tax matters, partnership proposed adjustments, and Form 3520-related penalties are pending in IRS Appeals - are interrelated and complex. In addition, the parties have also discussed potential and specific settlement scenarios as resolution discussions have progressed. They continue to believe that these cases are highly susceptible to settlement. For now they can stay on a status-report track, and it is
ORDERED that on or before September 6, 2024 the parties shall submit decision documents or file a status report describing their progress toward settlement or a narrowing of the facts to be tried.