Opinion
11505-20
08-07-2023
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 September 20, 2023 respondent shall file a motion for summary judgment or a status report explaining why he hasn't.