Opinion
32381-21L
09-28-2023
ORDER
LEWIS R. CARLUZZO, CHIEF SPECIAL TRIAL JUDGE
This I.R.C. section 6330(d) case is before the Court on respondent's motion for summary judgment, filed July 25, 2023. Respondent's motion was heard in Chicago, Illinois, on September 25, 2023. Counsel for respondent appeared and argued in support of the motion. Counsel for petitioner appeared and opposed the motion.
In order to allow for appropriate consideration of the positions of the parties, it is
ORDERED that respondent's motion is taken under advisement.