Opinion
14456-20
01-18-2023
P & L BURGERS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This case was on the Court's April 4, 2022 trial calendar for Los Angeles, California. We continued it because petitioner's next two tax years were in Exam. Petitioner has extensive records, but it appears that the tax year at issue in this case got accelerated into litigation because something went haywire in its audit. All agreed that it made sense to put this case on a status-report track and try to develop and likely settle (or at least coordinate) all three tax years together. They recently reported that the Commissioner has issued notices of deficiency for the later two years, and petitioner is preparing Tax Court petitions to challenge them. This is progress. The case can stay on a status-report track, and it is
ORDERED that on or before May 11, 2023 the parties shall file a status report describing their progress toward settlement or a narrowing of the issues to be tried.