Opinion
4254-23S
06-06-2023
MALEKA VIRANI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
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.