Opinion
7047-23
12-07-2023
GDEI GIRMAI TESFAMIKAEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On May 5, 2023, petitioner filed the petition in this case. On June 28, 2023, respondent filed the Answer, in which respondent alleges "that the Court's jurisdiction under I.R.C. §6015(e) is limited to reviewing the Commissioner's denial of the specific grounds contemplated by I.R.C. §6015(b), (c), and/or (f) from an otherwise existing joint and several liability." On December 7, 2023, the parties filed a Joint Proposed Stipulated Decision and a Joint Settlement Stipulation that include references to I.R.C. §6013(b)(2)(B).
Upon due consideration, it is
ORDERED that, on or before December 29, 2023, respondent shall file a report addressing: (1) the applicability of I.R.C. §6013(b)(2)(B) and (2) the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation.