Opinion
18196-23
02-20-2024
MYRIAM GOVEA PASSWATER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 24, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018 and to Strike. Respondent asserts that no notice of determination concerning relief from joint and several liability under I.R.C. section 6015 was issued to petitioner for tax year 2018, nor did respondent make, or fail to make, any determination for petitioner's 2018 tax year that would confer jurisdiction on the Court.
On February 14, 2024, petitioner filed a response to respondent's Motion. Petitioner appears to claim that she had requested innocent spouse relief for all the years from 2016 through 2021.
Upon due consideration, it is
ORDERED that, on or before March 12, 2024, respondent shall file a supplement to the above-referenced Motion, attaching thereto copies of any requests for relief from joint and several liability that petitioner filed with the I.R.S. for any of the years from 2016 through 2021.