Opinion
7349-20L
08-17-2021
DOREEN M. C. HEINTSCHEL, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER AND DECISION
Patrick J. Urda, Judge
This case is currently calendared for trial at the Court's San Diego, California, remote trial session, which is scheduled to begin September 20, 2021. On July 9, 2021, the Commissioner moved for summary judgment. On August 11, 2021, petitioner Doreen Heintschel filed a reply to motion for summary judgment, in which she acquiesced to the granting of the motion. Upon due consideration, it is
ORDERED that the Court's Order and Decision served on August 17, 2021, at docket entry #17, is hereby vacated and set aside. It is further
ORDERED that petitioner's reply to motion for summary judgment is hereby recharacterized as petitioner's response to motion for summary judgment. It is further
ORDERED that the Commissioner's motion for summary judgment, filed July 9, 2021, is granted. It is further
ORDERED and DECIDED that the determination set forth in the Notice of Determination Concerning Collection Action(s) Under Sections 6320 and/or 6330, dated March 6, 2020, for petitioner's income tax liability for the taxable years ending December 31, 2006, December 31, 2007, December 31, 2008, December 31, 2009, December 31, 2010, December 31, 2011, and December 31, 2012, upon which this case is based, is sustained in full.