Opinion
10164-20
07-18-2024
CATHERINE L. LAROSA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Ronald L. Buch, Judge.
Pending before the Court is the Commissioner's Motion to Dismiss for Lack of Jurisdiction filed November 10, 2020. Pursuant to the determination of the Court as set forth in its Opinion (163 T.C. No. 2) filed July 17, 2024, it is
ORDERED that the Clerk shall recharacterize the Commissioner's Motion to Dismiss for Lack of Jurisdiction filed November 10, 2020, as the Commissioner's Motion for Summary Judgment. It is further
ORDERED that the Commissioner's Motion for Summary Judgment filed November 10, 2020, is granted. It is further
ORDERED and DECIDED that petitioner is not entitled to innocent spouse relief under I.R.C. § 6015(f) for 1981 and 1982.