Opinion
24762-17
12-28-2021
Jesse C. Morreale Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
L. Paige Marvel Judge
On February 28, 2019, petitioner filed a motion for reasonable litigation or administrative costs. On May 15, 2019, respondent filed a response thereto. On July 15, 2021, the Court issued its Memorandum Opinion (T.C. Memo. 2021-90) in this case. Pursuant to the determination of the Memorandum Opinion filed July, 152021, the Court entered and served on the parties an order and decision on August 20, 2021, that among other things, granted petitioner's motion for reasonable litigation or administrative costs, filed February 28, 2019, and awarded to petitioner $15,034 for reasonable litigation costs.
On December 23, 2021, petitioner filed a motion to enforce overpayment determination. See Rule 260, Tax Court Rules of Practice and Procedure. Upon due consideration and for cause, it is
ORDERED that on or before January 24, 2022, respondent shall file a response to petitioners' motion to enforce overpayment determination.