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.