Opinion
5188-21S
02-23-2022
Courtney C. Ferguson & Steven S. Ferguson, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge
This case is calendared for trial at the April 18, 2022, Miami, Florida, Trial Session of the Court.
On January 11, 2022, petitioners filed a Motion for Reasonable Litigation or Administrative Costs (motion). By Order served January 18, 2022, the Court directed respondent, on or before February 22, 2022, to file a response to petitioners' motion. On February 18, 2022, respondent filed a Response to Motion for Reasonable Litigation or Administrative Costs (response), requesting that the motion be denied. In his response respondent stated that the motion was premature because this case is currently with the IRS Independent Office of Appeals and has not yet been resolved. Upon due consideration, it is
ORDERED that, on or before March 9, 2022, petitioners shall file a written reply to respondent's Response to Motion for Reasonable Litigation or Administrative Costs.