119 T.C. No. 19
UNITED STATES TAX COURT
ROSALINDA E. ALT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2964-01. Filed December 17, 2002.
P filed joint tax returns for taxable years 1982
to 1988 with H. H filed a return in 1989 with the
filing status of “Married filing separate”. P did not
file a tax return in 1989. R determined deficiencies
against P and H for taxable years 1982 to 1988. P sent
R a Form 8857, Request for Innocent Spouse Relief, for
taxable years 1982 to 1989. R sent P a notice of
determination determining that P was not entitled to
relief under I.R.C. sec. 6015(b), (c), and (f) for
taxable years 1982 to 1988. R sent P a letter
determining that no relief under I.R.C. sec. 6015 was
available for 1989 because P did not file a joint
return.
Held: Pursuant to I.R.C. sec. 6015(e), we have
jurisdiction to review the denial of P’s request for
relief under I.R.C. sec. 6015 for taxable years 1982 to
1988, and we have jurisdiction to review R’s failure to
make a determination on P’s request for relief under
I.R.C. sec. 6015 for 1989.
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