Opinion
24798-18
04-19-2022
ORDER
David Gustafson Judge
Trial in these consolidated cases--Nos. 24797-18, 24798-18, 20284-19, 20285-19--is scheduled to begin July 18, 2022. On April 18, 2022, the Commissioner filed in each case a motion for partial summary judgment on the issue of written supervisory approval of penalty under section 6751(b) (1). It is
ORDERED that, no later than May 16, 2022, petitioners shall file a response. It is further
ORDERED that, no later than June 6, 2022, the Commissioner shall file a reply.