Opinion
16285-21L
10-30-2023
ORDER
David Gustafson Judge
On October 30, 2023, we released our opinion in this "collection due process" ("CDP") case as T.C. Memo. 2023-130, stating that the Court will remand this case to the IRS's Office of Independent Appeals for further consideration. It is
ORDERED that jurisdiction over this case is retained by the undersigned judge, and that this case is remanded to the IRS's Office of Independent Appeals for the purpose of affording petitioner a supplemental administrative hearing. It is further
ORDERED that the IRS shall on or before January 2, 2024, offer to petitioner a supplemental hearing at a reasonable and mutually agreed upon date and time. Unless the parties agree otherwise, the supplemental hearing shall take place at the IRS's Office of Independent Appeals located closest to petitioner's residence (or at such other place as may be mutually agreed upon). It is further
ORDERED that the parties shall, on or before March 4, 2024, file with the Court a joint report (or, if that is not expedient, then separate reports), describing the status of the case and proposing a schedule for further proceedings, to which they shall attach a copy of any supplemental notice issued to petitioner.