Opinion
2240-22S
09-28-2023
JAMES A. FRASER & REBECCA K. FRASER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph Robert Goeke, Judge
This case is calendared for trial at the Session of the Court scheduled to commence on December 18, 2023, in Seattle, Washington.
On September 25, 2023, petitioners filed an Administrative Record. This document was improperly titled. The Court will recharacterize it as a request for innocent spouse relief under I.R.C. section 6015. The Court will direct petitioners to supplement this request with specific information as to why petitioner-wife qualifies as an innocent spouse. In this regard, petitioners should refer to I.R.C. section 6015 and the regulations thereunder. Accordingly, it is
ORDERED that petitioners are directed on or before October 31, 2023, to file with the Court a supplement as described above. It is further
ORDERED that petitioners' Administrative Record, filed September 25, 2023, shall be recharacterized as a Request for Innocent Spouse Relief under I.R.C. section 6015.
The parties are advised that this case remains set for trial on the above-referenced Trial Session.