Opinion
19924-21S
11-19-2021
Rickey E. LaPar Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
By notice of deficiency dated March 8, 2021, respondent determined a deficiency of $6,425 and an I.R.C. section 6662(a) accuracy-related penalty of $1,285 in petitioner's Federal income tax for the 2018 taxable year. On June 2, 2021, petitioner timely filed a petition for redetermination of the foregoing deficiency.
On October 8, 2021, the Court filed a letter dated September 29, 2021. Attached thereto is an apparent IRS Notice CP2000 issued to petitioner on September 20, 2021 (i.e., after the filing of the petition in this case), proposing to bill petitioner for the tax liability at issue in this proceeding. We will accordingly recharacterize this letter as a motion to restrain and direct respondent to file a response as set forth below.
Upon due consideration and for cause, it is
ORDERED that petitioner's letter dated September 29, 2021, is recharacterized as petitioner's Motion To Restrain Assessment or Collection or To Order Refund of Amount Collected. It is further
ORDERED that, on or before December 13, 2021, respondent shall file an objection, if any, to petitioner's above-referenced motion. Failure to comply with this Order may result in the granting of the motion to restrain.