Opinion
31001-21S
07-06-2023
ORDER
Kathleen Kerrigan, Chief Judge
This case for the redetermination of deficiencies is before the Court on petitioner's Motion to Restrain Assessment or Collection or to Order Refund of Amount Collected, filed April 27, 2022. On May 20, 2022, respondent filed a Response to the Motion and, on June 1, 2023, a First Supplement to that Response. Thereafter, on July 5, 2023, respondent filed an additional Supplement. A review of the record shows that the premature assessments for petitioner's 2017 and 2018 taxable years have been abated.
In consideration of the foregoing, it is
ORDERED that respondent's "First Supplement to First Supplement to Response to Motion to Restrain Assessment or Collection or to Order Refund of Amount Collected," filed July 5, 2023, is recharacterized as respondent's Second Supplement to Response to Motion to Restrain Assessment or Collection or to Order Refund of Amount Collected. It is further
ORDERED that petitioner's above-referenced Motion is denied as moot. Petitioner shall immediately notify the Court if collection action resumes before the final resolution of this case.