Opinion
16139-23
01-12-2024
PAUL DAVID EDNEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On November 8, 2023, petitioner in this collection case filed a document designated as a Motion to Withdraw, which is more in the nature of a Motion to Dismiss. Petitioner indicates that respondent has no objection to the granting of the motion. Notwithstanding that representation, we will direct respondent to file an objection, if any, to petitioner's motion.
Upon due consideration of the record in this case and for cause, it is
ORDERED that the Petition in this case shall be treated as a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d), It is further
ORDERED that the caption of this case is amended by adding the letter "L" to the docket number. It is further
ORDERED that the Clerk of the Court shall add the letter "L" to the docket sheet and other records of that office and process this case to trial or other disposition according to the Lien and Levy Action Procedures provided by Rules 330 et seq., Tax Court Rules of Practice and Procedure. It is further
ORDERED that petitioner's Motion to Withdraw is recharacterized as petitioner's Motion to Dismiss. It is further
ORDERED that on or before February 5, 2024, respondent shall file an objection, if any, to petitioner's just-referenced Motion to Dismiss.