Opinion
11794-20L
09-07-2021
Janet L. Kantor-Gluck, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER
ALBERT G. LAUBER JUDGE.
This collection due process (CDP) case is calendared on the Court's October 4, 2021, Los Angeles, California, trial session. On September 2, 2021, respondent filed a Motion to Remand this case to the IRS Independent Office of Appeals for a supplemental hearing. The purpose of the supplemental hearing would be to consider whether the penalties in question qualify for abatement for reasonable cause or under respondent's "first time abatement" policy. Respondent simultaneously filed a Motion for Continuance, and petitioner does not object to the granting of either Motion. In consideration of the foregoing, it is
ORDERED that respondent's Motion to Remand, filed September 2, 2021, is granted, and this case is remanded to the IRS Independent Office of Appeals for a supplemental CDP hearing. It is further
ORDERED that respondent shall offer petitioner a supplemental administrative hearing at a reasonable and mutually agreeable date and time, but no later than December 6, 2021. It is further
ORDERED that respondent's Motion for Continuance, filed September 2, 2021, is granted, and this case is stricken from the Court's October 4, 2021, Los Angeles, California, trial session and is continued. It is further
ORDERED that jurisdiction of this case is retained by the undersigned. It is further
ORDERED that respondent shall file with the Court, on or before January 7, 2022, a status report detailing the then-present status of the case. It is further
ORDERED that, if and when any supplemental notice of determination is issued to petitioner, respondent at that time shall file a status report and attach thereto a copy of the supplemental notice of determination.
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