Opinion
20410-19L
09-10-2021
Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Emin Toro Judge
This collection due process case is set for trial at the Court's November 15, 2021, Dallas, Texas, remote trial session. On September 9, 2021, respondent filed a Motion for Summary Judgment (Doc. 29), accompanied by two supporting Declarations of Jacob Russin (Docs. 30 & 31). The motion asserts that respondent did not abuse his discretion in sustaining the notice of intent to levy and rejecting the offers in compromise under the provisions of Internal Revenue Code section 6330. Upon due consideration, it is hereby
ORDERED that, on or before October 12, 2021, petitioner shall file with the Court a response to respondent's Motion for Summary Judgment. Failure by petitioner to respond as required by this Order may be deemed consent to the relief sought in the motion. It is further
ORDERED that, on or before October 26, 2021, respondent shall file a reply, if any, to petitioner's response.
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