- 2 - 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 hePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011