Opinion
16897-22L
03-05-2024
MARK ALOE & CAROL ALOE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Tamara W. Ashford, Judge
On March 4, 2024, pursuant to the Court's December 5, 2023, Order, respondent's counsel filed a Status Report, apprising the Court of the then present status of this case. Respondent's counsel reports that there was a delay in petitioners' amended federal income tax returns for the 2017 and 2018 taxable years and petitioners' federal income tax returns for the 2014-16 taxable years being reviewed by the Internal Revenue Service (IRS). Respondent's counsel further reports that the returns (and the substantiation for the returns) were recently assigned to an IRS employee for consideration when the delay was discovered; a final determination has not yet been made on the returns. According to respondent's counsel, after consideration of the returns (and the substantiation for the returns), the IRS Independent Office of Appeals will issue a supplemental notice of determination. Finally, respondent's counsel reports that upon receipt of the supplemental notice of determination, she will file a status report and provide the supplemental notice of determination to the Court. Upon due consideration, it is hereby
ORDERED that the parties shall, on or before June 3, 2024, file status reports, separately or jointly, apprising the Court of the then present status of this case, which shall include any Supplemental Notice of Determination Concerning Collection Actions Under Sections 6320 or 6330 of the Internal Revenue Code issued to petitioners.