Opinion
1599-21L
06-01-2023
DAVID H. HOFFMAN & HAGIT HOFFMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This collection due process case was on the Court's March 6, 2023 trial calendar for Dallas, Texas. It centers on a question of valuation that apparently affects the computation of petitioners' reasonable collection potential. Development has been a bit slow because petitioners are residents of Israel. The parties asked to have the case remanded to IRS Appeals, and recently reported a problem with later tax years that are also in litigation. They remain hopeful that this case and other tax years can all be worked out at the same time and will work on them this summer.
It is therefore
ORDERED that on or before August 22, 2023 the parties shall file a supplemental notice of determination, or respondent shall file a status report describing the parties' progress at IRS Appeals