Opinion
1719-17 1723-17
03-02-2023
PALMARINI INC., ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson Judge
Now pending is the computation under Rule 155 of the amounts of the decisions to be entered in these consolidated cases. On the Court's own motion, we will allow petitioners an extension of time to submit their computation.
Our order of December 7, 2022, ordered that, if the parties do not agree about the computation, then each party was to submit a computation in each case by March 7, 2023. On March 1, 2023, the Commissioner submitted his detailed computations. We think it is likely that petitioners, if they do disagree, may find it easier to critique the Commissioner's computations and to present corrected revisions thereof rather than to start from scratch and do their own. In case that is true, it is
ORDERED that petitioners' deadline to submit their computations is extended to March 31, 2023. As they compose those computations, they should keep in mind the instructions in our order of December 7, 2022, that
in submitting their computations under Rule 155, subsection (c) of that rule provides that
Any argument under this Rule will be confined strictly to consideration of the correct computation of the amount to be included in the decision resulting from the findings and conclusions made by the Court, and no argument will be heard upon or consideration given to the issues or matters disposed of by the Court's findings and conclusions or to any new issues. This Rule is not to be regarded as affording an opportunity for retrial or reconsideration.
It is further
ORDERED that, no later than April 17, 2023, the Commissioner shall file a reply (or, if petitioners have made no submission, then a status report so stating).