Opinion
6443-22S
05-30-2024
ORDER
Adam B. Landy Special Trial Judge
On March 29, 2022, Ms. Roundy electronically filed a Petition disputing the notice of deficiency issued to her for tax year 2019. On February 28, 2023, this case was set for trial at the Court's Salt Lake City, Utah, trial session commencing on June 20, 2023. On May 23, 2023, the Commissioner filed a status report stating that the parties reached a basis for settlement. Thereafter, Ms. Roundy raised the issue of whether she was liable for the early withdrawal additional tax, pursuant to section 72(t) of the Internal Revenue Code, to which the parties have been unable to resolve.
Since more than one calendar year has elapsed between the day the Petition in this case was filed and October 28, 2024, the date of the Salt Lake City, Utah, calendar call and to encourage communication while reducing the need for a continuance in this case, it is
ORDERED that, on or before July 31, 2024, the parties shall file written reports (jointly or separately): (1) identifying the specific issues remaining in dispute; (2) discussing whether the parties have met and conferred, either in person or by telephone, to discuss the issues remaining in dispute; (3) describing the efforts that the parties have undertaken or plan to undertake to settle this matter, and (4) informing the Court whether either party plans to file any pretrial motion(s) and, if so, the nature of such motion(s).
If either party believes a telephone conference would be helpful, please contact the undersigned's Chambers Administrator, Linda Thomas, at 202-521-0835 for scheduling purposes.