Opinion
14459-19
08-16-2021
Maria C. Ruiz, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER
Courtney D. Jones, Judge
This case is scheduled for trial at the remote trial session of the Court scheduled to commence at San Antonio, Texas, on September 27, 2021. On August 13, 2021, the Court held a conference call with the parties. During the call, the Court expressed its frustration that the notices of determination that form the basis of this case were not sent to Mrs. Ruiz via certified mail (as required by statute) and that respondent did not retain copies of them. The Court requests that the parties work together to discover, to the extent possible, copies of the notices of determination for the 2010, 2011, 2014, 2015, and 2016 tax years.
As noted above, this case contains innocent spouse claims for tax years preceding and succeeding the 2013 tax year. In light of that fact, respondent's counsel represented that respondent's counsel will not object if Mrs. Ruiz files a motion for leave to amend her petition to include the innocent spouse claim pertaining to the 2013 tax year.
Upon due consideration, it is therefore
ORDERED that, on or before September 7, 2021, the parties shall file joint or separate status reports and, to the extent possible, attach thereto complete copies of the notices of determination upon which this case is based.