Opinion
5513-20
11-09-2021
Stacey A. Moore Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On November 3, 2021, the Court received from the parties in the above-docketed matter a stipulated decision resolving this litigation. Review shows that petitioner has placed relief from joint and several liability pursuant to section 6015 of the Internal Revenue Code (I.R.C.), with respect to the 2016 taxable year at issue in the proceeding. Conversely, however, the record does not reflect issuance by respondent of a Notice of Filing of Petition and Right To Intervene in accordance with Rule 325 of the Tax Court Rules of Practice and Procedure. Hence, prior to entry of any stipulated decision, it is advisable to ensure compliance with relevant procedures.
Accordingly, upon due consideration, it is
ORDERED that, on or before November 23, 2021, respondent shall file a Notice of Filing of Petition and Right To Intervene reflecting service on the other individual filing the pertinent joint return. Appropriate action will then be taken in due course with respect to the stipulated decision received.