Opinion
24501-12 24504-12
01-26-2024
JOHNNY SANCHEZ, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
These cases were on the Court's January 27, 2014 trial calendar for San Francisco, California. The Court put them on a long-term status-report track to see what happened in a related criminal case and in petitioners' ongoing negotiations with IRS Appeals, and to allow respondent to decide petitioner Johnny Sanchez's request for innocent-spouse relief. It turned out these related issues also depended on the outcome of the criminal trial but, with delays caused by the pandemic, it took years before the parties finally reported that the criminal case had pled out. Progress was slow even after the criminal case was finished. By last year respondent sent a draft settlement to petitioners, but petitioners then wanted to review it with pro bono counsel. We learned today that petitioners had not been able to do so.
If the parties do not reach a settlement in the next three weeks, they should be prepared to try when the Court visits San Francisco in the spring. In the meantime, though, it is
ORDERED that the parties submit settlement documents or respondent file another status report on or before February 15, 2024 to describe the parties' progress toward settlement. If the parties have not settled respondent will also state the parties' respective estimates of the time it will take to try the cases.