Opinion
139-19L
04-18-2022
THOMAS RHEA HAMILTON & EDITH MARIE PALMER HAMILTON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
Pursuant to the determination of the Court as set forth in its Memorandum Opinion (T.C. Memo. 2022-21), filed March 15, 2022, it is hereby
ORDERED that this case is remanded to the Independent Office of Appeals for purposes of affording the petitioners a supplemental CDP hearing. It is further
ORDERED that the Commissioner shall offer the petitioners Thomas Rhea Hamilton and Edith Marie Hamilton a supplemental CDP hearing at a reasonable and mutually agreed upon date and time but no later than June 14, 2022. It is further
ORDERED that, on or before July 14, 2022, the parties shall file with the Court a joint status report (or separate reports, if that is more expedient), describing the then-present status of this case and proposing a schedule for further proceedings, and they shall attach thereto a copy of any supplemental notice issued to the Hamiltons.