Opinion
21941-22L
06-15-2023
ERIC WILFRED OLSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge
On June 5, 2023, petitioner filed a Motion for Leave to File First Amended Petition and a Brief in Support. Petitioner now seeks to assert innocent spouse relief on behalf of his spouse, Verlene Olson. Verlene Olson is not a party to this case, nor did she participate in the CDP hearing with the Independent Office of Appeals. Generally, innocent spouse relief is asserted by the spouse who will receive the benefit of the relief. See I.R.C. § 6015; Treas. Reg. § 1.6015-2. In filing this Motion for Leave, and viewing the pleading liberally, it appears the motion seeks to add Verlene Olson as a petitioner in this case.
Upon due consideration of the foregoing, it is
ORDERED that on or before July 7, 2023, respondent shall file a response to petitioner's Motion for Leave to File First Amended Petition.