Opinion
5229-23L
09-13-2023
PLURIA W. MARSHALL, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge.
This case is on the December 18, 2023 Los Angeles, California trial calendar. It's based on a notice of determination by the IRS to sustain a lien on Ms. Marshall's assets to collect eight quarters of unpaid section 6672 penalties. The parties took the initiative in requesting a conference call, which we had today. We learned that there is an at least colorable claim that petitioner should be able to challenge the liability. Respondent reasonably asked to have time to retrieve the administrative files, review them, and discuss the case with petitioner.
This will take some time, and it is ORDERED that this case is stricken from the Court's December 18, 2023 trial calendar. It is also
ORDERED that this division of the Court retains jurisdiction. It is also
ORDERED that on or before March 13, 2024 the parties shall file a status report to describe their progress in settling this case.