Opinion
12784-18
09-12-2024
VICTORIA JOY LE BEAU, PETITIONER AND CHARLES PAUL LE BEAU, INTERVENOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall Judge
On August 21, 2024, respondent filed a document entitled "Supplemental Motion for Summary Judgment", in which respondent requests that the Court grant partial summary judgment in respondent's favor on the issue of Victoria Le Beau's entitlement to relief from joint and several liability pursuant to I.R.C. section 6015(f) with respect to the taxable years at issue in this case. Upon due consideration, it is
ORDERED that respondent's "Supplemental Motion for Summary Judgment", filed August 21, 2024 at index no. 91 is recharacterized as respondent's Motion for Partial Summary Judgment, filed August 21, 2024. It is further
ORDERED that, because it appears material facts still remain in dispute, respondent's aforementioned Motion for Partial Summary Judgment, filed August 21, 2024, is denied without prejudice.