Opinion
19953-22SL
06-23-2023
DEARBORN FINANCIAL, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo Chief Special Trial Judge.
This I.R.C. section 6330(d) case is before the Court on respondent's motion for summary judgment, filed April 20, 2023. Respondent's motion was called for hearing in Chicago, Illinois, on June 20, 2023. Counsel for respondent appeared and requested leave to submit a memorandum of authorities in support of the motion. Premises considered, and for cause set forth more fully in the transcript of the above-referenced proceedings, it is
ORDERED respondent's motion is taken under advisement. It is further
ORDERED that respondent's memorandum of authorities, if respondent elects to submit one, is due not later than August 21, 2023.
The Court will take further action in this case as it deems appropriate.