Estate of Sanfilippo v. Comm'r

2015 Tax Ct. Memo LEXIS 33

Opinion

ESTATE OF MARTHA E. SANFILIPPO, DECEASED, WILLIAM J. SNYDER, EXECUTOR, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Sanfilippo v. Comm'r

Docket No. 18344-12L.

United States Tax Court

2015 Tax Ct. Memo LEXIS 33;

February 3, 2015, Decided

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Sanfilippo v. Comm'r (Estate of Sanfilippo), T.C. Memo 2015-15, 2015 Tax Ct. Memo LEXIS 16 (T.C., 2015)

For Petitioner: David W. Mitchell, Hoge, Fenton, Jones & Appel, San Jose, CA.

For Respondent: Nhi T Luu, Edith Green - Wendall Wyatt Fe, Portland, OR.

Michael B. Thornton, Chief Judge.

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Michael B. Thornton

ORDER

Pursuant to the determination of the Court as set forth in its , filed January 22, 2015, it is

ORDERED: That this case is remanded to respondent's Appeals Office for reconsideration of the estate's proposed collection alternatives taking into consideration any changed circumstances. It is further

ORDERED: That respondent shall offer petitioner an administrative hearing at respondent's Appeals Office at a mutually agreed upon place and at a reasonable and mutually agreed upon date and time, but no later than April 27, 2015. It is further

ORDERED: That the parties shall file a joint report regarding the current status of this case on or before May 11, 2015. It is further

ORDERED: That jurisdiction of this case is retained by the undersigned.

(Signed) Michael B. Thornton

Chief Judge

Dated: Washington, D.C.

February 3, 2015