Opinion
20882-21
07-31-2023
ALAN HAMEL & SUZANNE HAMEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge.
On July 24, 2023, the parties filed a joint status report in this case informing the Court of the present status of this case. Respondent represents that he anticipates filing a motion to dismiss the penalties from this case on the ground that penalties are not subject to the deficiency procedures of section 6320(a)(2)(A)(i). The parties indicated that all remaining issues in this case could be resolved with cross-motions for summary judgment.
Upon due consideration of the foregoing, it is
ORDERED that respondent shall file a Motion to Dismiss for Lack of Jurisdiction as to penalties, on or before August 25, 2023. It is further
ORDERED that all motions for summary judgment, or other dispositive motions, if any, shall be filed on or before September 22, 2023. It is further
ORDERED that all objections to dispositive motions, if any, shall be filed on or before November 21, 2023. It is further
ORDERED that all responses to objections of dispositive motions, if any, shall be filed on or before December 22, 2023.