Opinion
7350-20L
11-05-2021
Paul M. Daugerdas Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Joseph Robert Goeke Judge.
Upon due consideration of respondent's response and petitioner's memorandum, filed November 1, 2021, it is
ORDERED that the parties are directed on or before December 15, 2021, to file with the Court a memorandum addressing whether the assessments at issue were barred by I.R.C. section 6201(a)(4)(B).