Opinion
10562-21L
07-12-2023
JOHN D. LEVITAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones, Judge
On June 7, 2023, respondent filed an unopposed Motion to Close on Ground of Duplication with docket number 26762-21L (Doc. 24). Upon review of the records in both docketed cases, the Court recognizes that the notices of determination underlying the cases are substantially similar. For example, they address the same type of tax and tax periods. But because the notices bear different dates and section 6330(b)(2) provides one hearing per tax period, the Court would prefer that the parties clarify on the record their apparent view that the notice dated, June 29, 2021 (rather than the notice dated, February 26, 2021) reflects the tax periods on which the hearing was based.
In light of the foregoing, it is
ORDERED that this case is scheduled for a hearing on the above-referenced motion at the Court's August 23, 2023, Washington, DC, special hearing session to be conducted remotely at a date and time certain of 2:30 p.m. (Eastern Time). It is further
ORDERED that the Clerk of the Court shall serve on the parties a Notice of Remote Proceeding that shall contain comprehensive instructions on how to participate in the above-referenced remote proceeding.
Judge Courtney D. Jones will preside at the above-referenced hearing in lieu of Special Trial Judge Landy, who was previously assigned to the special session by the Chief Judge.