Opinion
12407-20SL
08-21-2023
MARK J. FEDEROWICZ & DIANE L. FEDEROWICZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
This case is calendared for trial at the Tampa, Florida, Trial Session of the Court scheduled to commence on December 18, 2023.
Petitioners filed a petition for review of a Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330. Petitioners appear to challenge the underlying tax liability for the tax years at issue, and they argue that the settlement officer abused her discretion in sustaining the proposed collection action.
The Court directs the parties to file reports: (1) identifying the specific issues remaining in dispute, (2) discussing whether the parties have met and conferred to discuss the issues remaining in dispute, (3) confirming whether the underlying liability somehow remains at issue in this case, (4) informing the Court whether either party plans to file any pretrial motion(s) and, if so, the nature of such motion(s), and (5) the status of the preparation of a stipulation of facts.
Upon due consideration, it is
ORDERED that, on or before September 21, 2023, the parties shall file with the Court a stipulation or certification of the administrative record in this case in accordance with Rule 93, Tax Court Rules of Practice and Procedure. It is further
ORDERED that, on or before October 31, 2023, the parties shall file written reports (jointly or separately) with the Court as more fully described in this order.