Opinion
4700-22SL
02-16-2023
MICHAEL R. HOLSEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy, Special Trial Judge.
This case is calendared for trial at the Standalone Remote Trial Session of the Court scheduled to commence on May 22, 2023.
Mr. Holsen filed a petition for review of a Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code. Mr. Holsen argues that respondent's Independent Office of Appeals improperly handled and rejected his request for a collection alternative.
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 is 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 the 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 March 20, 2023, the parties shall file written reports (jointly or separately) with the Court as more fully described in this order.