Opinion
8809-20L
10-26-2021
David Leuin Dannelley & Mariana Peralta Dannelley Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Patrick J. Urda Judge.
On October 20, 2021, the parties filed a proposed stipulated decision document.
Two questions must be resolved, however, before the Court can take action. First, it appears that the only Notice of Determination in the record was issued to Mariana Dannelley, and that the record contains no notice addressed to David Dannelley that would confer jurisdiction on this Court. Second, the proposed stipulated decision document references tax years 2009, 2011, and 2013. But the years at issue in the Notice of Determination issued to Mrs. Dannelley dated February 19, 2020, appear to be tax years 2011, 2012, and 2013 (with references to 2009, 2011, and 2013 on page two of the Notice). We will ask the Commissioner to explain our jurisdiction in light of these two points. Accordingly, it is
ORDERED that, on or before November 8, 2021, the Commissioner shall file a response to this Order.