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Ray v. Comm'r of Internal Revenue

United States Tax Court
Mar 1, 2023
No. 14564-22P (U.S.T.C. Mar. 1, 2023)

Opinion

14564-22P

03-01-2023

JAMES R. RAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

RONALD L. BUCH JUDGE

This case is calendared for trial at the Court's March 27, 2023, St. Paul, Minnesota, trial session. On January 26, 2023, the Commissioner filed a motion for summary and the Court ordered Mr. Ray to file a response by February 24, 2023. The Court did not receive a response from Mr. Ray.

On January 24, 2023, the Court issued the opinion in Belton v. Commissioner, T.C. Memo 2023-13, that addressed whether the Commissioner complied with the statutory requirements for making a section 7345 certification. The Commissioner's motion did not address Belton in his motion. To obtain the Commissioner's views on the application of Belton to this case, it is

ORDERED that, on or before March 24, 2023, each party shall file a response to this order addressing the issue of the statutory requirements under section 7345 addressed in Belton v. Commissioner, T.C. Memo 2023-13. It is further

ORDERED that this case is stricken from the above-referenced trial session, and the parties are excused from appearing at the calendar call on March 27, 2023. It is further

ORDERED that jurisdiction of this case is retained by the undersigned.


Summaries of

Ray v. Comm'r of Internal Revenue

United States Tax Court
Mar 1, 2023
No. 14564-22P (U.S.T.C. Mar. 1, 2023)
Case details for

Ray v. Comm'r of Internal Revenue

Case Details

Full title:JAMES R. RAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court:United States Tax Court

Date published: Mar 1, 2023

Citations

No. 14564-22P (U.S.T.C. Mar. 1, 2023)