Opinion
12416-22SL
01-03-2024
SAMUEL F. WILSON & PAMELA G. WILSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
Pending before the Court is the Commissioner's Motion to Remand, filed December 4, 2023. The Court ordered the Wilsons to file a response or an objection to the Commissioner's Motion on or before December 29, 2023. The Wilsons have failed to do so.
Upon due consideration of the Commissioner's Motion and for cause, it is ORDERED that the Commissioner's Motion to Remand, filed December 4, 2023, is granted. It is further
ORDERED that this case is remanded to the Commissioner's Independent Office of Appeals (Appeals Office) for further consideration consistent with the limited matters discussed in the motion as it relates to whether the Wilsons may challenge the underlying tax liability, including the abatement of any assessed and accrued interest, for taxable year 2019 in this proceeding. It is further
ORDERED that the Commissioner shall offer the Wilsons a supplemental administrative hearing at his Appeals Office located closest to their residence (or at such other place as may be mutually agreed upon) at a reasonable and mutually agreed upon date and time, but no later than April 30, 2024. It is further
ORDERED that, on or before May 31, 2024, the parties shall file with the Court a joint status report regarding the then-present status of this case and attach the supplemental notice of determination.