Virani v. Comm'r of Internal Revenue

Full title: MALEKA VIRANI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Jun 6, 2023

No. 4254-23S (U.S.T.C. Jun. 6, 2023)

Opinion

4254-23S

06-06-2023

MALEKA VIRANI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge

ORDER

Kathleen Kerrigan Chief Judge

The Petition in this case, which seeks relief from joint and several liability under I.R.C. section 6015, was served on respondent on March 28, 2023. On June 5, 2023, respondent, without leave, electronically filed a Notice of Filing of Petition and Right to Intervene. See Rule 325(a), Tax Court Rules of Practice and Procedure.

Upon due consideration and for cause, it is

ORDERED that respondent's Notice of Filing of Petition and Right to Intervene is recharacterized as respondent's Motion for Leave to File Out of Time Notice of Filing of Petition and Right to Intervene (Embodying Notice of Filing of Petition and Right to Intervene). It is further

ORDERED that respondent's Motion for Leave to File Out of Time Notice of Filing of Petition and Right to Intervene (Embodying Notice of Filing of Petition and Right to Intervene), filed June 5, 2023, is granted nunc pro tunc, and the Notice of Filing of Petition and Right to Intervene is filed as of such date.