Opinion
17512-21S
01-17-2023
CHRISTINE HANSEN & JAMES BOTTOMLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On September 10, 2021, petitioner filed a Motion to Restrain Assessment of Collection or to Order Refund of Amount Collected. On September 2, 2022, respondent filed an objection to petitioner's motion. In his objection, respondent states that the deficiency proposed in the notice of deficiency issued to petitioners was prematurely assessed and, on October 25, 2021, the premature assessment was abated. However, respondent did not state whether respondent placed a litigation hold on petitioners' account.
Upon due consideration, it is
ORDERED that, on or before February 7, 2023, respondent shall file a Supplement to his objection. In his Supplement, respondent shall state whether there is a litigation hold on petitioners' account.