Opinion
1599-21L
09-05-2023
DAVID H. HOFFMAN & HAGIT HOFFMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This collection due process case was on the Court's March 6, 2023 trial calendar for Dallas, Texas. It centers on a question of valuation that apparently affects the computation of petitioners' reasonable collection potential. Development was been a bit slow because petitioners are residents of Israel. The parties then reported a problem with later tax years that are also in litigation, but will soon be resolved. They remain hopeful that this case and other tax years can all be worked out at the same time and it is reasonable that it be
ORDERED that on or before November 22, 2023 the parties shall file a supplemental notice of determination, or respondent shall file a status report describing the parties' progress at IRS Appeals.