Opinion
15559-21S
11-29-2021
Anthony Aterno & Penelope Wilkov-Aterno Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On August 30, 2021, petitioners filed a letter, which the Court recharacterized as a motion to restrain assessment or collection or to order refund of amount collected. On November 22, 2021, respondent filed an objection to petitioners' motion, stating therein that the premature assessment with respect to petitioners' 2017 tax year has been abated. Respondent references a transcript dated November 22, 2021, for petitioners' account for the 2017 tax year, but no account transcript is attached to respondent's objection. Nor does respondent's objection discuss whether proper measures have been put in place to prevent further premature assessments with respect to petitioners' 2017 tax year.
Upon due consideration, it is
ORDERED that, on or before December 21, 2021, respondent shall file a supplement to his objection to motion to restrain assessment or collection or to order refund of amount collected and set forth therein information concerning the matters discussed above. Respondent shall also attach thereto a copy of the referenced account transcript for petitioners' 2017 tax year.