Opinion
804-22
08-18-2022
HABASUNE MUMBA & MIEASHA MARSHALL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 15, 2022, respondent filed a Response to the Court's Order served July 18, 2022. In that Response, respondent acknowledges that, after the timely filing of the Petition in this case, the deficiency and penalty determined in the Notice of Deficiency issued for petitioners' 2018 taxable year (i.e., the underlying tax liabilities at issue) were prematurely assessed. However, respondent advises that, following the issuance of the aforementioned Order, counsel for respondent requested the abatement of that premature assessment. Respondent further advises that the requested abatement posted to petitioners' account on August 15, 2022. Attached to respondent's Response is a copy of an account transcript generated on August 15, 2022, reflecting the posting of such an abatement.
Upon due consideration of the foregoing, it is
ORDERED that, if collection action relating to the underlying tax liabilities at issue resumes before the final resolution of this case, the parties shall immediately notify the Court.