Opinion
14574-20
09-22-2021
Linda E. Leon Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On August 20, 2021, the Court filed Thomas Leon's letter dated August 16, 2021. The letter does not provide Mr. Leon's mailing address, but the envelope bearing the letter lists a return address in Sea Cliff, New York. Upon further review, the letter appears to be more akin to a motion for leave to file notice of intervention out of time. See Rule 325(b), Tax Court Rules of Practice and Procedure.
Upon due consideration, it is
ORDERED that the above-referenced letter is recharacterized as Thomas Leon's Motion for Leave To File Notice of Intervention Out of Time. It is further
ORDERED that, on or before October 14, 2021, the parties shall each file a response to the above-referenced motion and, in addition to regular service, shall serve a copy of such response on Thomas Leon at the return address listed on the envelope bearing such motion. It is further
ORDERED that, in addition to regular service, the Clerk of the Court shall serve a copy of this Order on Thomas Leon at the return address listed on the envelope bearing the above-referenced motion.
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