Opinion
7562-19
03-15-2022
Faysal Warfa & Aisha Ibrahim Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Mark V. Holmes, Judge
This case was on the March 15, 2021 St. Paul, Minnesota trial calendar. Progress was complicated because the major issues are so unusual -- characterization of a small business's collection of funds used to invest in a building project in Ethiopa, and recharacterization of what the Commissioner thinks might be gross receipts but may be wire transfers received or made on behalf of Mr. Warfa's friends and acquaintances. Progress slowed and we finally imposed a deadline for petitioners to produce whatever documentation they had. In their recent status report the parties informed the Court that petitioners have now done so. They reasonably asked for two months for respondent to review these records and the parties to try to negotiate a settlement. It is therefore
ORDERED on or before May 17, 2022, the parties submit settlement documents or file a status report describing progress toward settlement or a narrowing of the issues to be tried in this case.