Opinion
17336-21
01-03-2022
Joseph Anthony Martino, Jr Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On December 2, 2021, petitioner filed a Motion To Restrain Assessment or Collection or To Order Refund of Amount of Collected. On December 29, 2021, respondent filed a Response to petitioner's motion to restrain. Among other things, in his Response respondent states that respondent's counsel has requested the IRS to: (1) abate the improper premature assessments made against petitioner for tax years 2017 and 2018, and (2) input a litigation hold on petitioner's account for 2018. Upon due consideration, it is
ORDERED that, on or before January 28, 2022, respondent shall file a First Supplement to his Response setting forth and discussing fully: (1) whether the IRS has now abated the improper premature assessments made against petitioner for tax years 2017 and 2018, and (2) whether the IRS has now inputted a litigation hold on petitioner's account for 2018.