Opinion
22865-22
05-10-2023
VIRGIL JOSEPH AIELLO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 4, 2023, respondent filed an Answer to the petition and attached thereto a copy of the notice of determination concerning collection action on which this case is based.
Upon due consideration of the foregoing, it is
ORDERED that this case shall be treated as a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d). It is further
ORDERED that the caption of this case is amended by adding the letter "L" to the docket number and the Clerk of the Court shall 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.