Opinion
7297-23L
07-25-2024
AMERICAN SOLAR ELECTRIC INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
This collection-due-process case was on the March 4, 2024 Las Vegas, Nevada trial calendar, but we remanded it to IRS Appeals for a supplemental hearing. In a telephone call today, both parties said that they expected IRS Appeals to issue a supplemental notice of determination shortly and that petitioner will want to challenge it. Both also agree that the Court will be able to decide the case on the basis of the administrative record. It is therefore
ORDERED that on or before September 25, 2024 the parties file a stipulated administrative record and a status report in which they propose a briefing schedule so the case can be submitted for decision. (That schedule should be for two rounds of simultaneous briefs.)