Opinion
22506-22L
10-19-2023
EDWARD WILLIAM ALLRED & RACHEL KING ALLRED,Petitioners v. COMMISSIONER OF INTERNAL REVENUE,Respondent
ORDER
Christian N. Weiler Judge
This case is currently set for trial at the Court's San Antonio, Texas trial session commencing on December 11, 2023. This case involves the appeal of a Notice of Determination made by the IRS's Office of Appeals with respect to petitioners' Collection Due Process hearing. On September 7, 2023, the Administrative Record related to this administrative appeal was lodged, and the parties filed a Stipulation as to the Administrative Record on September 11, 2023.
On October 12, 2023, respondent filed a Motion for Summary Judgment. While also on October 12, 2023, petitioners filed a Motion for Summary Judgment, along with a Motion to Remand. On October 12, 2023, petitioners also filed a Reply to respondent's Answer, which was filed on January 20, 2023. Under our Rules of Procedure, a Reply is due 45 days from the date of the filing of an Answer.
Considering the foregoing, it is
ORDERED that respondent's Motion for Summary Judgment and petitioners' Motion for Summary Judgment and Motion to Remand are hereby set for contradictory hearing at a date and time certain of 10:00 am (Central Time) on Tuesday December 12, 2023, at the Court's San Antonio trial session, in Room 371, 3rd Floor, Hipolito F. Garcia Federal Building & Courthouse, 615 E. Houston Street, San Antonio, Texas. It is further
ORDERED that on or before November 17, 2023, respondent shall file a response to petitioners' Motion for Summary Judgment and Motion to Remand. It is further
ORDERED that on or before November 17, 2023, petitioners shall file a response to respondent's Motion for Summary Judgment.