- 13 - 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. OPINION 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 (continued...)Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011