Opinion
16897-22L
12-05-2023
MARK ALOE & CAROL ALOE, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Tamara W. Ashford, Judge.
On November 21, 2023, pursuant to the Court's May 2, 2023, Order, respondent filed a Status Report, apprising the Court of the then present status of this case. Respondent reports that on August 23, 2023, a supplemental collection due process (CDP) hearing was conducted with petitioners' counsel. Respondent also reports that the representative from the Internal Revenue Service (IRS) Independent Office of Appeals (Appeals) assigned to conduct the supplemental CDP hearing granted petitioners until October 10, 2023, to resubmit Forms 1040X for the 2017 and 2018 taxable years, together with certain required substantiation. Respondent further reports that according to IRS records, the amended returns for 2017 and 2018, along with the 2014-2016 returns, were received by the IRS before October 30, 2023; the returns are now under consideration, and there has not yet been any determination made with respect to those returns. Finally, respondent reports that after consideration of the amended returns and the requested substantiation, Appeals will issue a supplemental notice of determination; upon receipt of the supplemental notice of determination, respondent will file a status report and provide the supplemental notice of determination to the Court. Upon due consideration, it is hereby
ORDERED that the parties shall, on or before March 4, 2024, file status reports, separately or jointly, apprising the Court of the then present status of this case, which shall include any Supplemental Notice of Determination Concerning Collection Actions Under Sections 6320 or 6330 of the Internal Revenue Code issued to petitioners.