Opinion
20686-22
06-14-2023
ORDER
Emin Toro Judge.
This case is currently calendared for trial during the Court's October 10, 2023, San Francisco, California, trial session. On May 25, 2023, petitioners filed a Motion for Summary Judgment (Doc. 11) and Briefs in Support of Motion for Summary Judgment (Docs. 12 & 13).
On June 12, 2023, the Court held a conference call with the parties to discuss, among other things, petitioners' pending Motion for Summary Judgment. During the call, respondent advised the Court that he is willing to accept the amended return provided by petitioners and that the amended return would result in a reduced deficiency. Respondent further advised the Court that this would make the substantial understatement penalty inapplicable.
The Court will hold in abeyance action on petitioners' Motion for Summary Judgment. Upon due consideration, it is hereby
ORDERED that petitioners' Motion for Summary Judgment is held in abeyance. It is further
ORDERED that, on or before July 12, 2023, the parties shall file with the Court either a joint report (or, if that is not expedient, then separate reports) describing the status of the case or a stipulated decision document.