Opinion
5025-23
07-01-2024
RAMEY KELLER, PETITIONER AND SHAWN KELLER, INTERVENOR, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case is on the May 20, 2024 St. Paul, Minnesota trial calendar. It is an innocent-spouse case, but an unusual one in that Ms. Keller filed her petition before the typical administrative procedure of initial determination by the IRS's CCISO followed by final determination by IRS Appeals played out. This might make for an interesting series of administrative-law questions about how to rule on a request for administrative relief unsupported by an administrative record that the law now defines as what we are ordinarily confined to reviewing.
The parties agreed earlier this year that it made sense to have respondent take some time to see if this case could be put back on a more normal track, which would allow both petitioner and intervenor to submit more information to first CCISO and then IRS Appeals as part of the administrative process. That remains the plan, and it is
ORDERED that on or before September 18, 2024 respondent shall file a status report to describe any progress toward settlement or preparing the case for trial.