Opinion
25835-21
03-11-2024
PAOLA FRUTIGER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge
This case involves a claim for innocent spouse relief filed by Paola Frutiger. On November 12, 2021, the Commissioner sent Paul Frutiger a Notice of Filing of Petition and Right to Intervene as required by Rule 325. Mr. Frutiger does not appear to have filed a notice of intervention in Ms. Frutiger's case.
It is possible that he chose not to intervene because he had an innocent spouse case of his own. Mr. Frutiger filed a separate petition from the Commissioner's denial of his claim for innocent spouse relief at Docket No. 31153-21. But the Court recently determined Mr. Frutiger's petition to be untimely and dismissed his case for lack of jurisdiction. Frutiger v. Commissioner, 162 T.C. No. 5 (2024). In light of that dismissal, we will provide Mr. Frutiger with another opportunity to intervene in Ms. Frutiger's case. Accordingly, it is
ORDERED that by May 10, 2024, Paul Frutiger may file a Notice of Intervention. It is further
ORDERED that the Clerk of Court shall serve Mr. Frutiger a copy of the Notice of Filing of Petition and Right to Intervene dated November 12, 2021, along with this Order.