Thomas Corson and Judith Corson - Page 12




                                       - 12 -                                         
                              (A) In general.--The individual may                     
                         petition the Tax Court (and the Tax Court                    
                         shall have jurisdiction) to determine the                    
                         appropriate relief available to the                          
                         individual under this section if such                        
                         petition is filed during the 90-day period                   
                         beginning on the date on which the Secretary                 
                         mails by certified or registered mail a                      
                         notice to such individual of the Secretary’s                 
                         determination of relief available to the                     
                         individual.  Notwithstanding the preceding                   
                         sentence, an individual may file such                        
                         petition at any time after the date which is                 
                         6 months after the date such election is                     
                         filed with the Secretary and before the close                
                         of such 90-day period.                                       
                              *    *    *    *    *    *    *                         
                         (4) Notice to other spouse.--The Tax Court                   
                    shall establish rules which provide the individual                
                    filing a joint return but not making the election                 
                    under subsection (b) or (c) with adequate notice                  
                    and an opportunity to become a party to a                         
                    proceeding under either such subsection.                          
                              *    *    *    *    *    *    *                         
                    (g) Regulations.--The Secretary shall prescribe                   
               such regulations as are necessary to carry out the                     
               provisions of this section, including--                                
                              *    *    *    *    *    *    *                         
                         (2) regulations providing the opportunity for                
                    an individual to have notice of, and an                           
                    opportunity to participate in, any administrative                 
                    proceeding with respect to an election made under                 
                    subsection (b) or (c) by the other individual                     
                    filing the joint return.                                          
          Additionally, the Restructuring Act directed the Secretary to               
          develop, within 180 days from the date of enactment, a form for             
          use by taxpayers in applying for relief under section 6015.  See            
          Restructuring Act sec. 3201(c), 112 Stat. 740.                              





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011