Opinion
2710-23SL
07-16-2024
PERPETUAL GAMING, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES JUDGE
This case was on the March 4, 2024 Las Vegas, Nevada trial calendar. The key dispute is about whether to include in the administrative record a handful of documents that petitioner thinks should be. The parties agreed that it would be reasonable to remand this case to IRS Appeals.
That worked. Respondent recently reported that Appeals determined that petitioner was eligible for an installment agreement. Respondent is optimistic that managerial approval of the installment agreement and issuance of a formal supplemental notice of determination in the case is imminent.
It is therefore
ORDERED that on or before August 23, 2024 the parties submit settlement documents, or respondent file a supplemental notice of determination or a status report describing their progress.