Opinion
10602-22 10721-22
04-02-2024
GAETANO PATRINOSTRO, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
The lower-numbered case was on the Court's May 1, 2023 San Francisco, California trial calendar. It's based on a notice of deficiency that the IRS sent to the owner of a restaurant in Sonoma County for his 2015 tax year. We learned earlier this year that the IRS had audited the Patrinostros for their 2016 tax year for similar reasons. We consolidated and moved them to a status-report track for now.
Respondent continues to report that petitioner promises that the two missing returns will soon be submitted. This is essentially what he reported last year, and the time may soon be coming when the Court will impose a strict deadline. But not quite yet. So we'll keep the cases on a status-report track, and it is
ORDERED that on or before April 29, 2024 respondent shall file a status report describing progress in completing discovery and moving these cases to settlement.