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Kelly Sue Tipton, pro se.
Darren L. Darilek, pro se.
Jennifer K. Martwick, for respondent.
OPINION
WELLS, Judge: The instant case is before the Court on
respondent’s motion to dismiss Darren L. Darilek (intervenor) for
failure properly to prosecute. Unless otherwise indicated, all
section references are to the Internal Revenue Code, as amended,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Background
Petitioner and intervenor filed a joint tax return for
taxable year 2002 and divorced in 2003. On March 8, 2005,
respondent issued a notice of deficiency determining a deficiency
of $7,173 in petitioner and intervenor’s Federal income tax for
taxable year 2002. Petitioner timely petitioned this Court for a
redetermination of the deficiency. During her Appeals
conference, petitioner requested relief from joint and several
liability pursuant to section 6015 (section 6015 relief). On
May 25, 2006, as required by Rule 325(a), respondent notified
intervenor of petitioner’s request for section 6015 relief and
of intervenor’s right to intervene. On July 27, 2006, intervenor
timely filed a notice of intervention with this Court in which he
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Last modified: May 25, 2011