Opinion
18502-22SL
10-03-2023
JEFFREY WEISBERG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
On September 29, 2023, the Commissioner filed a Status Report and attached thereto the Supplemental Notice of Determination, dated September 29, 2023, issued to Mr. Weisberg for taxable years 2015, 2016, and 2017 (years in issue). As set forth in the supplemental notice, the Commissioner's Independent Office of Appeals (Appeals) sustained the filing of the Notice of Federal Tax Lien (NFTL) because Mr. Weisberg failed to provide any financial information for which Appeals could determine if he qualified for a collection alternative. Appeals concluded that Mr. Weisberg failed to demonstrate that the NFTL was overly intrusive or that other collection alternatives are available, and that the filing of the NFTL balances the efficient collection of the taxes with the concern that the collection action be no more intrusive than necessary.
Accordingly, it is
ORDERED that, on or before November 13, 2023, the parties shall file either (1) a stipulated decision with the Court, (2) further written reports advising the Court of the progress made towards the resolution of the remaining issues in this case, by settlement or otherwise, or (3) a party may file an appropriate motion.
If the parties believe a telephone conference would be helpful, please contact the undersigned's Chambers Administrator at 202-521-0835 for scheduling purposes.