Opinion
15701-22
11-29-2023
HOLLY S. BOWER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
On June 28, 2022, petitioner filed the Petition and attached a Notice of Determination Concerning Relief from Joint and Several Liability Under Section 6015 to request relief from joint and several liability for tax year 2018. The Petition was served on July 14, 2022.
On November 21, 2023, docket entry 20, respondent filed with the Court a Motion for Leave to Notify Non-Requesting Spouse of Right to Intervene Out of Time. Respondent also lodged with the Court, at docket entry 21, a Notice of Filing of Petition and Right to Intervene.
Rule 325, Tax Court Rules of Practice and Procedure, provides that, with respect to actions for determination of relief from joint and several liability on a joint return, "[o]n or before 60 days from the date of service of the petition, the Commissioner shall serve a notice of the filing of the petition on the other individual filing the joint return and shall simultaneously file with the Court a copy of the notice with an attached certificate of service."
After due consideration, and for cause, it is
ORDERED that respondent's Motion for Leave to Notify Non-Requesting Spouse of Right to Intervene Out of Time, filed November 21, 2023, docket entry 20 is granted, and the Clerk of the Court shall file respondent's Notice of Filing of Petition and Right to Intervene, lodged November 21, 2023, docket entry 21, as of the date of this Order.