Opinion
2110-22SL
05-15-2023
ELENA IULIA HERA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
This case is calendared for trial at the New York, New York Trial Session of the Court scheduled to commence on September 18, 2023.
Ms. Hera filed a petition for review of a Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code. Ms. Hera appears to dispute the underlying tax liability for the tax year at issue.
The Court directs the parties to file reports: (1) identifying the specific issues remaining in dispute, (2) discussing whether the parties have met and conferred, either in person or by telephone, to discuss the issues remaining in dispute, (3) discussing whether the underlying liability remains at issue in this case, (4) describing the efforts that the parties have undertaken or plan to undertake to retrieve and compile an adequate administrative record to permit effective judicial review, (5) informing the Court whether either party plans to file any pretrial motion(s) and, if so, the nature of such motion(s), and (6) the status of the preparation of a stipulation of facts.
Upon due consideration, it is
ORDERED that, on or before July 11, 2023, Ms. Hera and the Commissioner shall file written reports (jointly or separately) with the Court as more fully described in this order.