Opinion
14482-22
11-14-2023
CHIOMA POWERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro, Judge.
The underlying Petition in this case seeks relief from joint and several liability pursuant to section 6015 of the Internal Revenue Code. Such cases are subject to the notice and intervention procedures set forth in Rule 325 of the Tax Court Rules of Practice and Procedure. The record does not reflect issuance by respondent of a Notice of Filing of Petition and Right to Intervene in accordance with Rule 325.
Accordingly, and for cause, it is
ORDERED that, on or before November 27, 2023, respondent shall file either (1) a Notice of Filing of Petition and Right to Intervene reflecting service on the other individual filing the pertinent joint return or (2) a status report.