Opinion
4647-23
02-27-2024
JONATHAN KOWALSKI & JENNAMARIE KOWALSKI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro, Judge.
Upon further review of the record in this case, it is hereby
ORDERED that, on the Court's own motion, the Petition in this case shall be treated as a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d). It is further
ORDERED that the caption of this case is amended by adding the letter "L" to the docket number. It is further
ORDERED that the Clerk of the Court shall add the letter "L" to the docket sheet and other records of his office and process this case to trial or other disposition according to the Lien and Levy Action Procedures provided by Rules 330 et seq., Tax Court Rules of Practice and Procedure.