Opinion
2133-21L
03-15-2023
HANS KARL KASPER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Elizabeth A. Copeland, Judge
This case is calendared for trial at the Trial Session of the Court scheduled to commence on April 3, 2023, in Atlanta, Georgia.
On March 9, 2023, the parties filed with the Court a Proposed Stipulated Decision. That decision document only addressed Section 6330 of the December 21, 2020, Notice of Determination. However, that Notice of Determination addressed both Section 6320 tax liens filed as to the 2011-2018 tax years and a proposed Section 6330 levy as to the 2011-2016 tax years.
Unless otherwise indicated, all statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times, all regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.
As it appears to the Court that the parties have reached agreement regarding sustaining the determination as to both Sections 6320 and 6330, we will enter a decision sustaining the Notice of Determination that was issued on December 21, 2020, and recharacterizing the Proposed Stipulated Decision as a Motion for Entry of Decision accordingly.
Upon due consideration, and for cause, it is
ORDERED that the "Proposed Stipulated Decision" filed with the Court on March 9, 2023, is recharacterized as a "Motion for Entry of Decision" and the Clerk is instructed to correct the docket entry accordingly. It is further
ORDERED that the above referenced Motion for Entry of Decision is granted. It is further
ORDERED AND DECIDED that the determinations set forth in the December 21, 2020, Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code for taxable periods 2011 through 2018 as to Section 6320 and taxable periods 2011 through 2016 as to Section 6330, are sustained in full.