Opinion
1683-21L
02-16-2022
Susan Anne Marrow Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
DAVID GUSTAFSON JUDGE
In response to a "Notice of Determination Concerning Collection Actions", petitioner Susan Anne Marrow filed her petition (Doc. 1) in this Court in January 2021, seeking relief under section 6015 (so-called "innocent spouse" relief) for the two years 2012 and 2014. However, the notice attached to her petition pertains only to 2014 and not to 2012. On February 14, 2022, the Commissioner filed a motion to dismiss in part, asking the Court to dismiss 2012 from this case. The motion explains that the IRS "did not issue petitioner a notice of determination concerning innocent spouse relief regarding taxable year 2012 because respondent made an administrative determination that petitioner is entitled to full innocent spouse relief regarding taxable year 2012, after application of I.R.C. § 6015(f)." The motion also states: "Petitioner informed respondent's counsel that she does not object to this motion. Respondent's counsel also informed petitioner of his conclusion that petitioner is entitled to full innocent spouse relief as to taxable year 2014. The parties therefore plan to electronically file a decision reflecting the settlement as to taxable year 2014 after the Court rules upon this motion." It is therefore
ORDERED that the Commissioner's unopposed motion to dismiss in part as to 2012 is granted, and that the petition is dismissed insofar as it requests relief for 2012. The Court will address the year 2014 in due course.