- 14 -
__, __ (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
9(...continued)
filed--
(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
(i)(I).
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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