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