Opinion
6021-22
01-30-2024
SUE-YEN PUPO, PETITIONER, AND ANTHONY J. VOCI, JR., INTERVENOR, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On January 12, 2024, the parties filed a Proposed Stipulated Decision. Based on a review of the record, it appears that in this case petitioner seeks to invoke our jurisdiction under I.R.C. section 6015(e). However, although the pleadings reference a notice of determination concerning relief from joint and several liability having been issued to petitioner for the taxable years 2011, 2012, and 2013, the record does not appear to include a copy of any such notice.
The foregoing considered, it is
ORDERED that, on or before February 21, 2024, respondent shall file a response to this Order and shall attach thereto a complete copy of the notice of determination concerning relief from joint and several liability upon which this case is based. It is further
ORDERED that action on the parties' Proposed Stipulated Decision shall be held in abeyance pending further direction by the Court.