Opinion
3619-24
08-15-2024
DANIEL J. KIM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion to Clarify Order, filed August 13, 2024, it is
ORDERED that respondent's above-referenced Motion is granted, in that it is
ORDERED that the second ordered paragraph of the Court's Order served July 25, 2024, that reads it is "ORDERED that respondent shall offer petitioner an administrative hearing with the Independent Office of Appeals at a reasonable and mutually agreed upon place, date, and time, but no later than October 25, 2024" is amended to read that it is "ORDERED that respondent shall offer petitioner an administrative hearing with the Independent Office of Appeals at a reasonable and mutually agreed upon place, date, and time, but no later than October 25, 2024. in order to determine whether the circumstances surrounding the late filing of petitioner's CDP hearing request warrant equitable tolling."