Opinion
6919-16L 7007-16L 7009-16L
05-22-2023
KATHERINE MASON, et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES JUDGE
We remanded this case to IRS Appeals for a supplemental CDP hearing, which led to petitioner's offering a compromise to the IRS. The parties recently reported that IRS Appeals has rejected that compromise and determined again that collection by levy is appropriate. These developments make it likely that the Court will have to review a substantially different administrative record if petitioner wishes to contest that supplemental determination. It is therefore
ORDERED that parties shall, on or before July 6, 2023, file with the Court the administrative record of respondent's supplemental notice of determination. It is also
ORDERED that simultaneous opening briefs are due on or before August 7, 2023 and simultaneous answering briefs are due on or before September 7, 2023. It is also
ORDERED that the parties may alter this schedule by stipulation filed with the Court.