Opinion
11581-20
08-03-2023
STEVEN FELLER & LOUISE FELLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge
On July 29, 2022, petitioners filed a Motion to Disqualify Counsel, moving to disqualify respondent's counsel of record, Jonathan Behrens. Petitioners moved to disqualify Mr. Behrens due to petitioners' intention to call Mr. Behrens as a witness in this case as related to respondent's lack of compliance with the supervisory approval requirement under section 6751(b).
On August 2, 2023, this Court granted respondent's Motion for Partial Summary Judgment and denied petitioners' Cross-Motion for Partial Summary Judgment on the issue of compliance with section 6751(b). Pursuant to that Order, we found that respondent complied with the requirements under section 6751(b) regarding supervisory approval.
Considering the foregoing, it is
ORDERED that petitioners' Motion to Disqualify Counsel, filed July 29, 2022, is denied as moot.