Opinion
3691-22L
03-20-2023
GUNASUNDRAN PILLAY & KALAIVANI GOVENDER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge.
This case was on the Court's September 12, 2022 San Francisco, California trial calendar. We continued it because the parties had not agreed on the contents of the administrative record and petitioners wanted to challenge the amount of the unpaid tax that the IRS says that they owe. Petitioners' challenge to that amount may be one that they have a legal right to, but that would depend on whether the administrative record shows they did not have a prior opportunity to challenge that liability. And even though they may not have a legal right to have the Court reconsider their tax liability, they may still try to do so bureaucratically through an IRS process called audit reconsideration. After a slowdown in progress, the parties recently reported that they may be nearing the end of negotiating a stipulated administrative record. It is therefore
ORDERED that on or before May 2, 2023 respondent shall file a status report to describe the parties' progress in agreeing to an administrative record, as well as any developments in petitioners' quest for audit reconsideration.