Opinion
15575-23
10-05-2023
TIMOTHY J. MURPHY & REBECCA A. MURPHY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 3, 2023, petitioners filed a document improperly titled Administrative Record, which consisted of a copy of the notice of determination concerning collection action on which this case is based.
Upon due consideration of the foregoing, it is
ORDERED that the Administrative Record, filed October 3, 2023, is recharacterized as an Exhibit to Petition. It is further
ORDERED that the petition in this case shall be treated as a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d). It is further
ORDERED that the caption of this case is amended by adding the letter "L" to the docket number. It is further
ORDERED that the Clerk of the Court shall add the letter "L" to the docket sheet and other records of her office and process this case to trial or other disposition according to the Lien and Levy Action Procedures provided by Rules 330 et seq., Tax Court Rules of Practice and Procedure.