Opinion
9228-19
08-17-2022
GEOFFREY B. SANDO & TERESA R. SANDO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro, Judge.
This case was calendared for trial during the Court's May 18, 2020, Los Angeles, California, trial session. By Order dated March 16, 2020, the Court continued the case from that session and the undersigned judge retained jurisdiction.
On March 25, 2020, respondent filed a Motion for Leave to File an Amendment to Answer (Doc. 8) and lodged the accompanying First Amendment to Answer (Doc. 9). On May 8, 2020, petitioners filed an Opposition to respondent's motion (Doc. 11). On June 12, 2020, respondent filed a Reply to petitioners' Opposition (Doc. 13).
On July 2, 2020, respondent filed a Motion to Dismiss and to Strike Partnership Items (Doc. 14). On July 23, 2020, petitioners filed an Objection to respondent's motion (Doc. 16).
On August 2, 2022, the parties filed a Joint Status Report (Doc. 39) informing the Court of the following:
The parties have agreed to a comprehensive settlement computation for the instant proceeding, which included pass-through adjustments related to TEFRA proceedings, that are now final. The parties have exchanged computations, which considered the affected items from the TEFRA proceedings, and the parties agree with the computations.
On August 9, 2022, the Court held a conference call with the parties to discuss the current status of the case. The parties request additional time to file a decision document. The additional time will allow the parties to "confirm[] whether additional administrative actions will be required to effectuate the parties' settlement across this case and the [related] TEFRA cases, before drafting a [p]roposed [d]ecision in the instant proceeding."
Upon due consideration, it is hereby
ORDERED that respondent's Motion for Leave to File an Amendment to Answer (Doc. 8) is denied without prejudice to respondent's right to renew if necessary to effect the parties' settlement. It is further
ORDERED that respondent's First Amendment to Answer lodged on March 25, 2020, shall remain lodged for purposes of the record in this case and will not be filed. It is further
ORDERED that respondent's Motion to Dismiss and to Strike Partnership Items (Doc. 14) is denied without prejudice to respondent's right to renew if necessary to effect the parties' settlement.