Opinion
31799-21S
03-31-2023
LEONEL C. ALVARADO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 30, 2023, respondent filed a Motion for Leave to File Out of Time Notice of Filing of Petition and Right to Intervene and concurrently lodged a Notice of Filing of Petition and Right to Intervene. Respondent states in his motion that, in a recent telephone call with petitioner, petitioner raised a claim for relief from joint and several liability (innocent spouse relief). However, except for respondent's just-described motion, there is nothing in the Court's record indicating that petitioner seeks innocent spouse relief.
Upon due consideration of the foregoing, it is
ORDERED that, on or before April 25, 2023, if petitioner intends to seek in this case relief from joint and several liability, petitioner shall file a Response to this Order indicating that intention. The Court will hold respondent's above-referenced motion pending a response from petitioner.