Opinion
6032-23
02-06-2024
LISA M. HOLLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
This case is calendared for trial during the Court's April 15, 2024, Washington, D.C., trial session. The Petition in this case was filed on April 22, 2023, and it contains unredacted confidential information. Tax Court Rule 27(a) generally provides that parties should refrain from including (or should take appropriate steps to redact) confidential information such as taxpayer identification numbers, social security numbers, and financial account numbers. The Court will seal petitioner's Petition to protect the confidential information appearing in it.
The docket number originally assigned to this case was "6032-23L," indicating that it was a collection due process (CDP) case. On April 24, 2023, the docket number was amended by omitting "L." On July 27, 2023, petitioner filed a document that the Court docketed as her Reply to Answer. In this document petitioner states that she filed the Petition in response to a "notice of Due Process Lien" that she received from the IRS on March 22, 2023. On February 1, 2024, respondent filed with the Court what he contends to be the administrative record of this case. See Tax Court Rule 93. Appearing as Exhibit 8-R is a "notice of determination" for tax years 2011 and 2017- 2019. That notice, bearing the subject line "Due Process - Lien," is addressed to petitioner and is dated March 22, 2023. Because this case appears to be a CDP case, we will direct the Clerk of the Court to amend the docket number accordingly.
For cause, it is
ORDERED that, on the Court's own motion, the unredacted Petition filed in this case on April 22, 2023, is sealed from public view. It is further
ORDERED that the caption of this case is amended by adding the letter "L" to the docket number. It is further
ORDERED that the Clerk of the Court shall add the letter "L" to the docket number in this case and other records of her office and process this case to trial or other disposition according to the Lien and Levy Action Procedures provided by Rules 330 et seq., Tax Court Rules of Practice and Procedure.