Opinion
23237-18L
05-30-2023
JAMES WILLIAM AVERY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber, Judge
This collection due process (CDP) case involves petitioner's tax years 2008-2013. On February 21, 2023, the Court filed an Opinion (T.C. Memo. 2023-18) in which we decided various issues related to petitioner's underlying tax liabilities for these years, including his liability for additions to tax. By Order served March 28, 2023, we directed the parties to file a status report expressing "their agreement as to what petitioner's aggregate underlying liability for 2008-2013 would be-including tax, additions to tax, and interest-if calculated in accordance with the Court's Opinion."
On May 25, 2023, respondent filed a status report in the case. In consideration of information contained in the report, it is
ORDERED that the parties shall file with the Court, on or before July 25, 2023, a joint status report consistent with the directions set forth in our Order served March 28, 2023.