Opinion
18196-23
03-12-2024
MYRIAM GOVEA PASSWATER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On January 24, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018 and to Strike (Motion), asserting therein that no notice of determination concerning relief from joint and several liability under I.R.C. section 6015 was issued to petitioner for tax year 2018, nor did respondent make, or fail to make, any determination for petitioner's 2018 tax year that would confer jurisdiction on the Court. On February 14, 2024, petitioner filed a response to respondent's Motion, asserting therein that she had requested innocent spouse relief for all the years from 2016 through 2021. On February 20, 2024, the Court directed respondent to file a supplement to the Motion, attaching thereto copies of any requests for relief from joint and several liability that petitioner filed with the I.R.S. for any of the years from 2016 through 2021.
On March 8, 2024, petitioner electronically filed a document that was labeled as a "Response to Order resp. by 3-12-24 shall file supplement to motion to dismiss." This document was titled by petitioner "First Supplement in Response to Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018 and to Strike."
Upon due consideration, and for cause, it is
ORDERED that petitioner's filing at Docket Entry No. 13 is recharacterized as petitioner's First Supplement in Response to Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018 and to Strike. It is further
ORDERED that the time for respondent to file a supplement to the above-referenced Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018 and to Strike is extended to April 2, 2024.