Opinion
11519-20L
10-27-2022
MICHAEL D. BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber, Judge
Petitioner filed a motion for summary judgment in this collection due process on July 22, 2021. We heard oral argument on that motion during the Court's March 28, 2022, Los Angeles, California, trial session. By Order served June 23, 2022, we denied petitioner's motion for the reasons set forth in the Court's Opinion issued that same day. See Brown v. Commissioner, 158 T.C. No. 9 (2022).
On October 25, 2022, respondent filed a Motion for Partial Summary Judgment. In substance this is a cross-motion directed to the same issue that was decided in our Opinion. Respondent contends that the logic of our Opinion dictates, not only the denial of petitioner's motion, but also the granting of respondent' cross-motion.
Upon due consideration, it is
ORDERED that, on or before November 9, 2022, petitioner shall file with the Court and serve on respondent's counsel a response to the Motion for Partial Summary Judgment, filed October 25, 2022.