Opinion
13860-20
10-05-2023
DEBORAH LYNN JOHNSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Cary Douglas Pugh Judge
This case was stricken from the Court's June 12, 2023, Milwaukee, Wisconsin trial session and continued, and jurisdiction was retained by this Division of the Court. On August 31, 2023, respondent filed a Status Report advising that respondent sent petitioner stipulated decision documents "grant[ing] her relief from joint and several liability for her review and consideration" and requesting additional time to submit stipulated decision documents or filed further reports. We directed the parties to submit stipulated decision documents or file status reports by October 2, 2023.
On September 29, 2023, respondent filed a Motion for Entry of Decision reiterating respondent's conclusion that "petitioner is entitled to relief from joint and several liability for the taxable year 2016 for all of the joint tax liability assessed against her and her former spouse that is not attributable to income that she herself earned". Attached to respondent's motion is a letter respondent received from petitioner explaining that she has failed to receive relief from other Courts and administrative proceedings, and that she did not sign the stipulated decision document because she "feel[s] [her] concerns have not been heard by the Court."
It appears that petitioner is not satisfied with the relief granted by respondent. We are a Court of limited jurisdiction, see I.R.C. sec.7442, and may exercise jurisdiction only to the extent expressly authorized by federal statute. See, e.g., Breman v. Commissioner, 66T.C.61,66 (1976). We are unclear what relief petitioner seeks beyond that respondent has conceded in his motion that she is entitled to receive. Upon due consideration and for cause, it is hereby
ORDERED that, on or before November 6, 2023, petitioner shall file an objection to respondent's Motion for Entry of Decision addressing specifically the relief she claims she should receive beyond that conceded in respondent's motion and the basis for her claim.