Lisa H. Green - Page 2




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          whether we have jurisdiction under section 6015(e)2 over                    
          petitioner’s stand-alone case asserting a claim for equitable               
          relief under section 6015(f) for 1995, 1996, 1997, and 1998.                
                                     Background                                       
               Petitioner resided in Florida when the petition in this case           
          was filed.                                                                  
               Petitioner filed joint Federal income tax returns for the              
          years at issue with her former husband, Jonathan H. Green.                  
          Petitioner paid the Federal income tax liabilities reported on              
          the 1995, 1996, 1997, and 1998 joint returns but did not pay the            
          tax liabilities reported on the 1999 and 2000 joint returns.                
          Respondent has not asserted a deficiency against petitioner for             
          any year at issue.                                                          
               On February 3, 2003, respondent received petitioner’s Form             
          8857, Request for Innocent Spouse Relief, with a Statement                  
          Regarding Request for Equitable Relief (statement) for 1995                 
          through 2000 attached.  In the statement, petitioner requested a            
          refund of tax paid for 1995 through 2000 under section 6015(f).             
               On March 24, 2006, respondent issued to petitioner a Notice            
          of Determination Concerning Relief from Joint and Several                   
          Liability Under Section 6015 for 1999 and 2000, in which he                 
          denied petitioner’s request for relief.  Respondent, however, did           


               2Unless otherwise indicated, all section references are to             
          the Internal Revenue Code.                                                  






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