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Sando v. Comm'r of Internal Revenue

United States Tax Court
Aug 17, 2022
No. 9228-19 (U.S.T.C. Aug. 17, 2022)

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.


Summaries of

Sando v. Comm'r of Internal Revenue

United States Tax Court
Aug 17, 2022
No. 9228-19 (U.S.T.C. Aug. 17, 2022)
Case details for

Sando v. Comm'r of Internal Revenue

Case Details

Full title:GEOFFREY B. SANDO & TERESA R. SANDO, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Aug 17, 2022

Citations

No. 9228-19 (U.S.T.C. Aug. 17, 2022)