Opinion
8246-22L
06-16-2023
LAWRENCE D. CONWAY & BARBARA G. CONWAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall, Judge.
Upon due consideration of respondent's Motion to Remand, filed June 14, 2023, it is
ORDERED that respondent's aforementioned motion is granted, and this case is remanded to respondent's Office of Appeals for the purpose of affording petitioners an administrative hearing pursuant to I.R.C. section 6330. It is further
ORDERED that respondent shall offer petitioner an administrative hearing at respondent's Appeals Office located closest to petitioners' residence (or at such other place as may be mutually agreed upon) at a reasonable and mutually agreed upon date and time, but no later than September 18, 2023. It is further
ORDERED that the parties shall, on or before October 18, 2023, file with the Court a joint report or separate reports as to the then present status of this case. If respondent's Office of Appeals has issued petitioners a supplemental notice of determination at that time, the parties shall attach such notice to their reports. It is further
ORDERED that respondent's Motion for Summary Judgment, filed April 6, 2023, is denied as moot. It is further
ORDERED that jurisdiction is retained by this Division of the Court.