118 T.C. No. 31
UNITED STATES TAX COURT
GWENDOLYN A. EWING, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1940-01. Filed May 31, 2002.
P and H filed a joint return. A portion of the
tax shown on the return was not paid. R has not
asserted a deficiency against P or H. P submitted to R
a request for relief from joint and several liability
under sec. 6015, I.R.C. R mailed a notice of
determination denying P relief under sec. 6015(b), (c),
and (f), I.R.C. The notice of determination was not
mailed to P’s last known address. P actually received
the notice of determination by the 88th day after the
notice was mailed. The envelope containing P’s
petition was postmarked 92 days after the mailing of
the notice of determination. The petition was received
and filed 99 days after the date R mailed the notice of
determination. The petition was filed more than 6
months after P submitted her request for relief to R.
Held: We have jurisdiction to determine whether P
is entitled to equitable relief under sec. 6015(f),
I.R.C., regarding the underpayment of tax shown on P’s
joint return.
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