Sandrus L. Collier - Page 13

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          years to relief under section 6015(f)8 because:  (1) Ms. Collier            
          knew and had reason to know of the underpayment of tax for each             
          of the years 1987 through 1991, and (2) under all the facts and             
          circumstances, it would not be inequitable to hold Ms. Collier              
          liable for the tax for each of those years.                                 
               We first address Ms. Collier’s position that the Court lacks           
          jurisdiction over her request for relief under section 6015(f)              
          for taxable years 1990 and 1991.  In support of that position,              
          Ms. Collier contends that she did not jointly file tax returns              
          with Mr. Collier for those years.                                           
               The Court’s jurisdiction in the instant case is dependent              
          upon section 6015(e)(1).9  See Ewing v. Commissioner, 118 T.C.              

               8Respondent also denied, and Ms. Collier concedes that she             
          is not entitled to, relief under sec. 6015(b) and (c).                      
               9Sec. 6015(e) provides in pertinent part:                              
               SEC. 6015.  RELIEF FROM JOINT AND SEVERAL LIABILITY ON                 
                    JOINT RETURN.                                                     
                    (e) Petition for Review by Tax Court.--                           
                         (1) In general.-–In the case of an individual                
                    against whom a deficiency has been asserted and                   
                    who elects to have subsection (b) or (c) apply--                  
                              (A) In general.–-In addition to any                     
                         other remedy provided by law, the individual                 
                         may petition the Tax Court (and the Tax Court                
                         shall have jurisdiction) to determine the                    
                         appropriate relief available to the individ-                 
                         ual under this section if such petition is                   

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