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years to relief under section 6015(f)8 because: (1) Ms. Collier
knew and had reason to know of the underpayment of tax for each
of the years 1987 through 1991, and (2) under all the facts and
circumstances, it would not be inequitable to hold Ms. Collier
liable for the tax for each of those years.
OPINION
We first address Ms. Collier’s position that the Court lacks
jurisdiction over her request for relief under section 6015(f)
for taxable years 1990 and 1991. In support of that position,
Ms. Collier contends that she did not jointly file tax returns
with Mr. Collier for those years.
The Court’s jurisdiction in the instant case is dependent
upon section 6015(e)(1).9 See Ewing v. Commissioner, 118 T.C.
8Respondent also denied, and Ms. Collier concedes that she
is not entitled to, relief under sec. 6015(b) and (c).
9Sec. 6015(e) provides in pertinent part:
SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON
JOINT RETURN.
(e) Petition for Review by Tax Court.--
(1) In general.-–In the case of an individual
against whom a deficiency has been asserted and
who elects to have subsection (b) or (c) apply--
(A) In general.–-In addition to any
other remedy provided by law, the individual
may petition the Tax Court (and the Tax Court
shall have jurisdiction) to determine the
appropriate relief available to the individ-
ual under this section if such petition is
(continued...)
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