Opinion
34310-21L
03-08-2023
ALBERT T. SUNGLAO & GICELLE YADAO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
This case is on the calendar of the Court's April 3, 2023 trial session for San Francisco, California. On March 1, 2023, respondent filed a Motion to Remand asking the Court to remand this case to respondent's Appeals Office for further consideration.
We will grant respondent's motion. Likewise, the Court provided a list of tax clinics in the San Francisco area that may represent petitioners free of charge if they meet certain qualifications. A copy of the list is attached to this Order.
Upon due consideration and for cause, it is
ORDERED that this case is stricken from the above-referenced trial session, and the parties are excused from appearing at the calendar call on April 3, 2023. It is further
ORDERED that respondent's Motion to Remand is granted, and this case is remanded to respondent's Appeals Office for the purpose of affording petitioners an administrative hearing pursuant to I.R.C. §§ 6320 and 6330 to satisfy petitioners' unpaid income tax liabilities for tax years 2015 through 2017, and the proposed collection action under I.R.C. § 6320 to satisfy petitioners' tax liability for tax year 2018. It is further
ORDERED that respondent shall offer petitioners an administrative hearing at such place as may be mutually agreed upon (or by teleconference if preferable) at a reasonable and mutually agreed upon date and time, but no later than May 5, 2023. It is further
ORDERED that on or before September 6, 2023, the parties shall file with the Court status reports (a joint report, if possible) concerning the then-current status of this case. It is further
ORDERED that jurisdiction of this case is retained by the undersigned.