115 T.C. No. 40
UNITED STATES TAX COURT
CLIFFORD W. MILLER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10563-99L. Filed December 21, 2000.
Held: Sec. 6015, I.R.C., has no application to,
and does not govern, (1) the request of P’s former
spouse for relief from joint and several liability
under sec. 6013(e), I.R.C. (former sec. 6013(e)), which
was repealed effective July 22, 1998, and (2) the
administrative proceedings conducted by R that ulti-
mately resulted in R’s granting that relief to her
prior to July 22, 1998. Held, further, P did not have
the right to be notified of or to participate in the
administrative proceedings relating to the request of
P’s former spouse for relief from joint and several
liability under former sec. 6013(e). Held, further, P
lacks standing to challenge respondent’s determination
to grant P’s former spouse relief from joint and sev-
eral liability under former sec. 6013(e). Held, fur-
ther, respondent did not abuse respondent’s discretion
with respect to any of the determinations in the notice
of determination concerning collection action under
sec. 6320 and/or 6330, I.R.C.
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