Opinion
4605-24
07-11-2024
YVONNE MARIE GREEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 25, 2024, petitioner Yvonne Marie Green filed the Petition to commence this case, indicating therein that she seeks review of a notice of determination concerning collection action issued for her 2014 tax year. However, petitioner filed as an Attachment to Petition only a notice of determination concerning relief from joint and several liability under section 6015 issued with respect to her 2014 tax year. Therefore, while this Court has jurisdiction with respect to the 2014 notice of determination concerning relief from joint and several liability under section 6015, we appear to lack jurisdiction with respect to a notice of determination concerning collection action issued for petitioner's 2014 tax year. On July 5, 2024, Gavan Green filed in this case a Notice of Intervention.
Upon due consideration of the foregoing, it is
ORDERED that the caption of this case is amended to read: "Yvonne Marie Green, Petitioner and Gavan Green, Intervenor v. Commissioner of Internal Revenue, Respondent". It is further
ORDERED that, on or before August 2, 2024, respondent shall file either an appropriate jurisdictional motion with respect to so much of this case relating to a notice of determination concerning collection action issued for petitioner's 2014 tax year or a written report concerning the then-current status of this case.