Opinion
17338-22SL
06-21-2023
MJS FINANCIAL LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy, Special Trial Judge
This collection due process case is calendared for trial at the Standalone Remote Trial Session of the Court scheduled to commence on November 13, 2023.
The Court filed a petition received from Martin Schandelson, on behalf of MJS Financial, LLC (the "Company"), seeking review of a Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 for the tax period at issue. The Company argues that it does not owe the tax liability at issue, and the settlement officer abused his discretion in sustaining the proposed levy action.
The Court directs the parties to file reports: (1) identifying the specific issues remaining in dispute, (2) discussing whether the parties have met and conferred, either in person or by telephone, to discuss the issues remaining in dispute, (3) confirming whether the underlying liability remains at issue in this case, (4) informing the Court whether either party plans to file any pretrial motion(s) and, if so, the nature of such motion(s), and (5) the status of the preparation of a stipulation of facts.
Upon due consideration, it is
ORDERED that, on or before August 4, 2023, the parties shall file with the Court a stipulation or certification of the administrative record in this case in accordance with Rule 93, Tax Court Rules of Practice and Procedure. It is further
ORDERED that, on or before September 14, 2023, the Company and the Commissioner shall file written reports (jointly or separately) with the Court as more fully described in this order.