Opinion
16576-22SL
06-27-2023
THU L. TRAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Lewis R. Carluzzo, Chief Special Trial Judge
In a bench opinion rendered on May 23, 2023, and served on June 21, 2023, in this I.R.C. section 6330(d) case, the Court ruled that respondent may proceed with collection as determined in a notice of determination. In a letter dated May 16, 2023, received by the Court on May 30, 2023, but not yet filed, petitioner explained his failure to appear at the May 23, 2023, hearing in Philadelphia, Pennsylvania. In his letter, petitioner also continues to advance his challenge to the underlying liability, which, for reasons explained in the bench opinion, he is not entitled to do in this proceeding. Premises considered, it is
ORDERED that as the date of service of this Order and Decision, the Clerk of the Court file petitioner's letter as petitioner's motion for reconsideration of the bench opinion. It is further
ORDERED that petitioner's motion is denied. It is further
ORDERED and DECIDED that pursuant to the determination of the Court as set forth in the above-referenced bench opinion, respondent may proceed with collection as determined in the Notice of Determination, dated June 9, 2022, a copy of which is attached to the petition.