Opinion
3743-24
04-26-2024
JEREMY D. ALLEN & JENNIFER A. ALLEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 25, 2025, respondent filed in the above-docketed matter a document under the designation "Motion To Strike". However, review shows that, in nature, the subject of the submission would be more properly addressed by means of a Motion To Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015 (or Failure of IRS to Make Determination Within 6 Months After Election or Request for Relief).
Accordingly, the premises considered, it is
ORDERED that respondent's April 25, 2024, Motion To Strike is denied. It is further
ORDERED that, on or before May 17, 2024, respondent shall file a proper jurisdictional motion seeking dismissal of this case in part as to a purported Motion To Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015 (or Failure of IRS to Make Determination Within 6 Months After Election or Request for Relief).