Opinion
16571-21L
08-10-2023
ARSENAL ENERGY USA, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
This case is on the calendar of the Court's September 11, 2023, trial session for Denver, Colorado. On August 4, 2023, respondent filed a Motion to Remand asking the Court to remand this case to respondent's Independent Office of Appeals (Appeals Office) for further consideration. Respondent represents that petitioner does not object to the granting of the motion. Upon due consideration and for cause, it is
ORDERED that this case is stricken from the above-referenced trial session, and the parties are excused from appearing at the calendar call on September 11, 2023. It is further
ORDERED that respondent's Motion to Remand is granted, and this case is remanded to respondent's Appeals Office for the purposes of affording petitioner an administrative hearing pursuant to I.R.C. sections 6320 and 6330, and conducting a review of petitioner's unpaid income tax liability for tax year 2016. It is further
ORDERED that respondent shall offer petitioner an administrative hearing at such place as may be mutually agreed upon (or by teleconference if preferable) at a reasonable and mutually agreed upon date and time, but no later than November 7, 2023. It is further
ORDERED that on or before February 9, 2024, the parties shall file with the Court a status report (a joint report, if possible, otherwise separate reports) concerning the then-current status of this case. It is further
ORDERED that jurisdiction of this case is retained by the undersigned.