Opinion
19335-21L
08-29-2024
HA TRAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
This case was on the Court's September 12, 2022 trial calendar for San Francisco, California. Ms. Tran is a native speaker of Vietnamese and has limited English skills. She had applied for innocent-spouse relief in response to the IRS's decision to collect her unpaid 2008, and 2010-2012 taxes, and seemed to be in difficult financial circumstances. But the chief reason for the lack of progress is that the IRS lost its administrative file for this case. Respondent reasonably suggested that we treat this absence of a record as an inadequate record - inadequate records in CDP cases justify remands for the creation of a supplemental record. We therefore remanded the case to IRS Appeals and respondent reported earlier this summer that the Appeals Office agreed that Ms. Tran is entitled to relief.
We recently checked our docket and saw that the case has not closed, however, so it is
ORDERED that on or before October 28, 2024 the parties shall submit settlement documents or respondent shall file a status report describing how to bring this case to a close.