Opinion
12128-23L
09-26-2023
ELEVEN WILLOW COURT, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of the Motion to Remand, filed September 21, 2023, it is
ORDERED that the above-referenced Motion is granted, and this case is remanded to respondent's Independent Office of Appeals respondent's Office of Appeals for the purpose of affording petitioner an administrative hearing pursuant to section 6320 and/or 6330 of the Internal Revenue Code (I.R.C.). It is further
ORDERED that respondent shall offer petitioner an administrative hearing at a reasonable and mutually agreed upon date and time, but no later than December 26, 2023. It is further
ORDERED that the parties shall, on or before January 16, 2024, file with the Court a joint report regarding the then-present status of this case, attaching thereto a copy of any supplemental notice of determination issued.