Opinion
11505-20
03-30-2023
MICHAEL RUNNELS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
This case involves an unusual corner of tax law arising from an American resident of Australia. We put it on a status-report track to enable the parties to complete informal discovery. Respondent recently reported that he may then move for partial summary judgment. This may take some time, so it is
ORDERED that on or before June 20, 2023 the parties shall file a status report describing their progress in completing informal discovery and moving toward summary judgment.