Opinion
13684-21L
03-18-2022
John R. Cifelli Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Christian N. Weiler Judge
This case is calendared for trial during the Court's May 16, 2022, New York City, New York trial session. On March 17, 2022, respondent filed a Motion for Summary Judgment in respondent's favor of all issues presented in this Collection Due Process ("CDP") case, and a declaration in support thereof. The motion states that petitioner's views are unknow.
Upon due consideration, it is
ORDERED that on or before April 15, 2022, petitioner shall file with the Court and serve on respondent's counsel a response to the Motion for Summary Judgment.