Opinion
23510-22L
07-07-2023
AMANDA IRIS GLUCK IRREVOCABLE TRUST, ADAM ROMAN, TRUSTEE, Petitioner(s) v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
This collection due process (CDP) case was continued from the Court's June 20, 2023, New York, New York, trial session. On July 5, 2023, the Internal Revenue Service (IRS or respondent) filed a Motion for Summary Judgment. In this Motion, the IRS contends that there are no disputed issues of material fact in the case, that no trial is necessary, and that the IRS is entitled to judgment as a matter of law.
In consideration of the foregoing, it is
ORDERED that, on or before August 7, 2023, petitioner shall file with the Court a Response to respondent's Motion for Summary Judgment. In its Response petitioner shall explain in detail why it believes equitable tolling is justified on the facts of this case.