Opinion
20468-21L
04-04-2023
PIPER TRUCKING & LEASING, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MAURICE B. FOLEY JUDGE
On November 9, 2022, the Court filed respondent's Motion for Summary Judgment. For cause, it is
ORDERED that respondent shall, on or before April 18, 2023, file a supplemental motion for summary judgment and explain in detail how penalties pursuant to 6721(e) are calculated using electronic means.