Opinion
30649-13
07-15-2022
DAN E. PATTERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
EMIN TORO JUDGE
This case was assigned to the undersigned judge for trial or other disposition on January 31, 2020. As requested by the parties, this case was being held in abeyance pending a final decision of the Eighth Circuit Court of Appeals in Coffey v. Commissioner, 987 F.3d 808 (8th Cir. 2021), rev'g and remanding 150 T.C. 60 (2018). That case is now final, certiorari having been denied on January 10, 2022.
On April 4, 2022, the parties filed a Joint Status Report (Doc. 20) informing the Court that the parties have discussed settlement and that respondent's counsel is coordinating with the United States Competent Authority to see whether petitioner will receive credit for a payment made in 2005. By Order served April 7, 2022, the parties were directed to file on or before July 6, 2022, either a status report or a stipulated decision document.
The parties having failed to file a status report or a stipulated decision document on or before July 6, 2022, Court personnel emailed both counsel for petitioner and respondent to get the current status of the case.
On July 14, 2022, respondent filed a Status Report (Doc. 22) informing the Court that "[o]n June 15, 2022, counsel for respondent emailed petitioner's counsel proposed language for a decision document to settle the case, and inquired whether petitioner was in agreement with that language or had an alternative proposal. Counsel for respondent has not received an answer as of the date of this filing."
Upon due consideration, it is hereby
ORDERED that, on or before July 29, 2022, the parties shall file with the Court either a joint report (or, if that is not expedient, then separate reports) describing the status of the case or a stipulated decision document.