Opinion
2710-23SL
04-25-2024
PERPETUAL GAMING, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This case was on the March 4, 2024 Las Vegas, Nevada trial calendar. We continued it and encouraged the parties to compile the administrative record and stipulate to a briefing schedule. They have not been able to do so, and we spoke with them today to discuss how to move the case forward.
The key dispute is whether a handful of documents that petitioner thinks should be part of the administrative record. The parties agree that it would be reasonable to remand this case to IRS Appeals and let petitioner give these documents to the appeals officer to review. If this doesn't lead to a settlement, it will at least lead to a supplemental notice of determination supported by an administrative record that the parties would likely be able to agree on.
It is therefore
ORDERED that this case is remanded to respondent for a supplemental CDP hearing. It is also
ORDERED that on or before July 8, 2024 the parties submit settlement documents, or respondent file a supplemental notice of determination or a status report describing their progress.