Opinion
24466-22
05-23-2023
MARILYNN STATEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
The underlying petition in this case seeks relief from joint and several liability pursuant to section 6015 of the Internal Revenue Code. Such cases are subject to the notice and intervention procedures set forth in Rule 325 of the Tax Court Rules of Practice and Procedure. Although the parties' Proposed Stipulated Decision, filed May 16, 2023, acknowledges that petitioner is seeking innocent spouse relief for tax years 2008 through 2015, the record does not reflect issuance by respondent of a Notice of Filing of Petition and Right to Intervene in accordance with Rule 325.
Accordingly, and for cause, it is
ORDERED that, on or before June 9, 2023, respondent shall serve on the other individual filing the joint returns at issue in this case a Notice of Filing of Petition and Right to Intervene and shall file a copy thereof with the Court in accordance with Rule 325(a), Tax Court Rules of Practice and Procedure. It is further
ORDERED that the parties' Proposed Stipulated Decision shall be held in abeyance pending further direction from the Court.