Opinion
20894-19 6791-20 10830-20 17749-21 17771-21
09-01-2023
NOEL M. PARDUCCI & KENNETH L. PARDUCCI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge
By order dated June 16, 2022, the Court consolidated these five cases. On August 4, 2023, Jeffrey D. Hoyal & Lori D. Hoyal and Crater Lake Trust moved for a partial summary judgment on two issues. The "primary issue" of their motion (as they characterized it) is whether the statute of limitations has expired. The statute of limitations issue is predicated on a question of fact, namely whether the facts support the application of the false return exception of section 6501(c)(1). The secondary issue is whether adjustments under section 481 are warranted. On this secondary issue, we will order further briefing. Accordingly, it is
ORDERED that the Commissioner shall file a Response (with respect to the section 481 issue) to the Hoyal's Motion for Partial Summary Judgment by October 6, 2023. It is further
ORDERED that the Hoyals and Crater Lake Trust may file a Reply to the Commissioner's Response by October 27, 2023.