Opinion
24668-21
04-27-2022
NANCY JOAN AGNEW & PETER DOUGLAS AGNEW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
For the reasons set forth in Boechler, P.C. v. Commissioner, No. 20-1472 (U.S. April 21, 2022), it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction, filed November 4, 2021, as supplemented February 9, 2022, and April 22, 2022, in the above-docketed matter is denied. It is further
ORDERED that the Clerk of the Court is directed to add the letter "L" to the docket record and other records of the Court and to 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. It is further
ORDERED that, on or before May 23, 2022, respondent shall file an appropriate jurisdictional motion taking into account Boechler, P.C. v. Commissioner, No. 20-1472 (U.S. April 21, 2022), i.e., with respect to the case insofar as pertains to petitioner Peter Douglas Agnew.