Opinion
17254-22
07-09-2024
ERNEST D. WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Upon due consideration of respondent's Status Report filed on July 8, 2024, it is
ORDERED that, on or before August 9, 2024, the parties shall file a joint report and shall address therein the application of I.R.C. sections 6512(b)(3) and 6511(b)(2) to the facts of this case and whether the overpayment in this case is barred by the statute of limitations.