Opinion
9202-23L
09-16-2024
WILMAUD REALTY CORP., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro, Judge
This collection due process case was calendared for trial during the Court's June 3, 2024, New York, New York, trial session. On June 3, 2024, the Court called and recalled this case at its New York, New York, trial session and held a partial trial. Later on June 3, 2024, respondent informally notified Court personnel that "[t]he parties have reached an agreement to remand this case for consideration of an offer in compromise."
On June 4, 2024, the parties filed a Joint Motion to Remand (Doc. 38) asking the Court to remand the case to the IRS Independent Office of Appeals (IRS Appeals) for further consideration. By Order served June 10, 2024, the parties' Joint Motion to Remand was granted and this case was remanded to the IRS Appeals for further consideration, including a supplemental administrative hearing, consistent with the parties' Joint Motion to Remand.
On September 3, 2024, the parties filed a Joint Motion for Continuance (Doc. 55) requesting that the "Court [] extend the deadline for the supplemental hearing by 60 days, to November 8, 2024, with a corresponding extension of the status report deadline to December 9, 2024." Upon further review of this Motion, it appears to be a Joint Motion for Extension of Time.
Upon due consideration, it is hereby
ORDERED that the parties' Joint Motion for Continuance filed September 3, 2024, is recharacterized as the parties' Joint Motion for Extension of Time. It is further
ORDERED that the time in which respondent shall offer petitioner the supplemental hearing at the IRS Appeals office located closest to petitioner's principal place of business (or at such other place as may be mutually agreed upon) at a reasonable and mutually agreed date and time is extended from September 9, 2024, to November 8, 2024. It is further
ORDERED that the time in which the parties shall file with the Court a joint report (or, if that is not expedient, then separate reports) describing the status of the case is extended from October 9, 2024, to December 9, 2024.