Opinion
631-24
03-26-2024
CHELSIE AZEVEDO & MARCIO CAVALCANTE DE AZEVEDO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 24, 2024, petitioners made an electronic filing with the Court, designating the filing as a First Supplement to Petition. Review of the filing shows that it consists of a copy of Internal Revenue Service Form 8857, Request for Innocent Spouse Relief, that has been completed and signed by petitioner Chelsie Azevedo. As this is a case for the redetermination of a deficiency, and petitioner Chelsie Azevedo is seeking to amend the Petition herein to raise as an affirmative defense a claim for relief from joint and several liability under I.R.C. section 6015, it is
ORDERED that petitioners' First Supplement to Petition is recharacterized as petitioners' First Amendment to Petition. It is further
ORDERED that, within 60 days from the date of service of this Order, respondent shall file an answer to the First Amendment to Petition.