Opinion
2023-20S
09-24-2021
Anibal M. Caseiro Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Cary Douglas Pugh, Judge
This is an action for redetermination of a deficiency for tax year 2017, currently calendared on the Court's November 29, 2021, Miami, Florida remote trial session. A review of the petition suggests that petitioner seeks relief from joint and several liability under I.R.C. section 6015, i.e., so-called "innocent spouse" relief. Rule 325(a), Tax Court Rules of Practice and Procedure, provides that respondent shall file with the Court a copy of the Notice of Filing of Petition and Right to Intervene that respondent served on the other individual filing the joint return with petitioner for the year before the Court. As directed by the Court, respondent filed a Motion for Leave to File Out of Notice of Filing of Petition and Right to Intervene, and lodged a Notice of Filing of Petition and Right to Intervene, on September 15, 2021. Respondent states that there is no objection to this motion. Upon due consideration and for cause, it is hereby
ORDERED that respondent's Motion for Leave to File Out of Time Notice of Filing of Petition and Right to Intervene, filed September 15, 2021, is granted, and the Notice of Filing of Petition and Right to Intervene, is deemed filed as of the date of this Order.
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