Opinion
12834-20SL
02-15-2023
NANCY B. MCDOUGAL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy, Special Trial Judge.
This case is calendared for trial at the Trial Session of the Court scheduled to commence on March 13, 2023, in Phoenix, Arizona.
On February 3, 2023, respondent filed a Motion for Continuance and a Motion to Remand this case to respondent's Independent Office of Appeals (Appeals) for further consideration. Respondent requested this case be remanded to Appeals for a supplemental Collection Due Process hearing so that the settlement officer can review petitioner's collection alternative after filing all delinquent tax returns. As it appears a remand will conserve judicial resources and be in the best interest of justice, such remand will be granted.
Upon due consideration of respondent's motions and for cause, it is
ORDERED that respondent's Motion for Remand, filed February 3, 2023, is granted and this case is remanded to respondent's Independent Office of Appeals for further consideration. It is further
ORDERED that respondent shall offer petitioner a supplemental administrative hearing at respondent's Independent Office of Appeals located closest to petitioner's residence (or at such other place as may be mutually agreed upon) at a reasonable and mutually agreed upon date and time, but no later than June 30, 2023. It is further
ORDERED that, on or before July 31, 2023, the parties shall file with the Court a status report (preferably a joint status report) regarding the then-present status of this case and attach the supplemental notice of determination. It is further 1
ORDERED that this case is stricken from the Trial Session of the Court scheduled to commence on March 13, 2023, in Phoenix, Arizona. It is further
ORDERED that respondent's Motion for Continuance, filed February 3, 2023, is denied as moot. It is further
ORDERED that jurisdiction of this case is retained by the undersigned. 2