Opinion
12416-22SL
02-16-2023
SAMUEL F. WILSON & PAMELA G. WILSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
ADAM B. LANDY, SPECIAL TRIAL JUDGE
This case is calendared for trial at the Washington, District of Columbia, Trial Session of the Court scheduled to commence on May 30, 2023.
Petitioners filed a petition for review of a Notice of Determination Concerning Collection Actions under IRC Sections 6320 or 6330 of the Internal Revenue Code. The Court directs the parties to file reports: (1) identifying the specific issues remaining in dispute, (2) discussing whether the parties have met and conferred, either in person or by telephone, to discuss the issues remaining in dispute, (3) discussing whether the underlying liability is at issue in this case, (4) describing the efforts that the parties have undertaken or plan to undertake to retrieve and compile an adequate administrative record to permit effective judicial review, (5) informing the Court whether the party plans to file any pretrial motion(s) and, if so, the nature of such motion(s), and (6) the status of the preparation of a stipulation of facts.
Upon due consideration, it is
ORDERED that, on or before March 30, 2023, the parties shall file written reports (jointly or separately) with the Court as more fully described in this order. It is further
ORDERED that, on or before March 30, 2023, respondent shall file a response to this Order and attach thereto a complete copy of the notice of determination for tax year 2019 on which this case is based.