Sandrus L. Collier - Page 14

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          __, __ (2002); Fernandez v. Commissioner, 114 T.C. 324, 330-331             
          (2000); Butler v. Commissioner, 114 T.C. 276, 289-290 (2000).  We           
          conclude that the joint filing of a tax return is not a prerequi-           
          site to the Court’s jurisdiction under that section.10  We reject           
          Ms. Collier’s position that we do not have jurisdiction over                
          taxable years 1990 and 1991 because she did not jointly file tax            
          returns with Mr. Collier for those years.                                   
               We next address Ms. Collier’s position that respondent                 
          should not have denied her request for relief under section                 
          6015(f) with respect to each of the taxable years 1988 through              

                              (i) at any time after the earlier of--                  
                                   (I) the date the Secretary mails,                  
                              * * * notice of the Secretary’s final                   
                              determination of relief available to the                
                              individual, or                                          
                                   (II) the date which is 6 months                    
                              after the date such election is filed                   
                              with the Secretary, and                                 
                              (ii) not later than the close of the                    
                         90th day after the date described in clause                  
               10Although our jurisdiction under sec. 6015(e)(1) is not               
          dependent on spouses’ jointly filing a tax return, a taxpayer is            
          not entitled to relief under sec. 6015 for a taxable year if such           
          taxpayer did not jointly file a tax return with such taxpayer’s             
          spouse for that year.  See sec. 6015; Rev. Proc. 2000-15, 2000-1            
          C.B. 447, 448.  We address below Ms. Collier’s contention that              
          she did not jointly file tax returns with Mr. Collier for 1990              
          and 1991.                                                                   

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