Opinion
12031-21SL
11-22-2023
JOSEPH ANDREW ABBOTT & PAMELA ABBOTT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
On November 17, 2023, respondent filed a Status Report and reported that respondent's Independent Office of Appeals held a supplemental hearing for petitioners on September 20, 2023, but petitioners did not call in to the scheduled hearing. Further, respondent indicates that petitioners have not submitted Form 433-A or other supporting documentation to support their request for a collection alternative. Accordingly, respondent's Independent Office of Appeals issued a supplemental notice of determination to petitioners sustaining the levy on November 15, 2023.
Upon due consideration and for cause, it is
ORDERED that, on or before January 19, 2024, respondent shall file the Supplemental Notice of Determination.