Opinion
11964-20L
04-26-2022
MARIO G. FERNANDEZ & MARIA E. FERNANDEZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall, Judge
On September 30, 2020, petitioners timely filed their petition. Attached to the petition is a notice of determination, dated August 27, 2020, addressed solely to petitioner, Maria E. Fernandez, sustaining a notice of federal tax lien filing concerning federal income tax liabilities for the taxable years 2014 and 2015. The attachment to the notice of determination also references petitioner, Mario G. Fernandez.
On March 15, 2022, the parties filed a proposed stipulated decision. That decision addressed the notice of determination dated August 27, 2020 and issued solely to petitioner, Maria E. Fernandez, for the taxable years 2014 and 2015. Accordingly, the Court issued an order directing respondent to file a report including a complete copy of the notice of determination concerning collection actions that was issued to Mario G. Fernandez for the taxable years at issue. On April 20, 2022, respondent filed a status report attaching thereto an undated notice of determination addressed to both petitioners sustaining a proposed levy (i.e., not a notice of federal tax lien filing) for the taxable years 2016, 2017, and 2018 (i.e., not the years at issue in this case).
To ensure that the Court has jurisdiction to render a decision in this case with respect to both petitioners, Mr. and Mrs. Fernandez, the Court will direct respondent and petitioner, Mrs. Fernandez, to file a report as set forth below.
The foregoing considered, it is
ORDERED that, on or before May 13, 2022, respondent and petitioner Maria E. Fernandez, shall each file a report and shall attach thereto a complete copy of the notice of determination concerning collection actions that was issued to petitioner, Mario G. Fernandez, for the taxable years 2014 and 2015, if any.