Opinion
9648-18
11-17-2022
VICTORIA D. WOODS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, Respondent AND RICHARD T. AVIS, INTERVENOR, Petitioners
ORDER
Eunkyong Choi, Special Trial Judge.
Pending before the court is petitioner's and intervenor's Motion for Leave to File Second Amendment to Petition, filed December 23, 2020. Petitioner and intervenor request that the Court permit them to amend the petition to add causes of action for promissory estoppel and equitable estoppel. The instant motion is substantially similar to the motion petitioner and intervenor filed previously, on June 29, 2020, where they requested that the court permit them to amend the petition to add a cause of action for recission. We denied the June 29, 2020 motion noting that in a "stand-alone" innocent spouse relief case, such as this case, the Court's jurisdiction is limited to reviewing petitioner's request for relief from an existing joint and several tax liability and determining whether such relief is available under subsection (b), (c), or (f) of section 6015. We will likewise deny petitioner's and intervenor's Motion for Leave to File Second Amendment to Petition. We do not have jurisdiction to decide whether respondent is estopped from denying petitioner's request for innocent spouse relief.
Upon due consideration, it is
ORDERED that petitioner's and intervenor's Motion for Leave to File Second Amendment to Petition, filed December 23, 2020, is denied.