Opinion
8574-21S
09-08-2022
ORDER
Kathleen Kerrigan, Chief Judge.
On March 15, 2021, the petition was filed challenging a notice of deficiency for tax year 2018. In it petitioner seeks relief from joint and several liability pursuant to section 6015 of the Internal Revenue Code. On September 6, 2022, the parties filed a Proposed Stipulated Decision, reflecting respondent's concession that petitioner is entitled to relief from joint and several liability under I.R.C. section 6015(b) with respect to the taxable year 2018. Under Rule 325(a), Tax Court Rules of Practice and Procedure, respondent should have served "notice of the filing of the petition on the other individual filing the joint return" and filed a copy of that notice with the Court. See King v. Commissioner, 115 T.C. 118, 125 (2000). None has been filed.
Upon due consideration and for cause, it is hereby
ORDERED that, on or before October 5, 2022, respondent shall serve on the other individual filing the joint return at issue in this case a Notice of Filing of Petition and Right to Intervene and shall file a copy thereof with the Court in accordance with Rule 325(a), Tax Court Rules of Practice and Procedure.