- 3 - On August 9, 1999, petitioner requested relief with respect to the 1993 liability under section 6015(b), (c), and (f). On March 27, 2001, respondent issued a notice of determination granting petitioner partial relief pursuant to section 6015(c). The notice stated that petitioner had requested relief in the amount of $24,093, that relief had been granted in the amount of $20,367, and that there was tax remaining of $3,729.3 The notice also stated that refunds were not allowed with respect to section 6015(c) relief. Petitioner filed a petition in this Court seeking relief pursuant to section 6015. He requests that this Court: determine that Petitioner is eligible for relief under Section 6015 in the amount of $20,367.00 and direct the Internal Revenue Service to issue a refund to Petitioner in the amount of $20,367.00, together with statutory interest thereon, pursuant to Section 6015 of the Internal Revenue Code. Respondent argues that any refund is barred by section 6015(g)(3). Section 6015, as amended, was originally enacted in 1998 to replace former section 6013(e). Internal Revenue Service 2(...continued) trial that the excess was applied to assessed interest. Neither party specifically addressed this point, but respondent presumably has relieved petitioner from liability for any remaining unpaid interest. 3It is unclear what the basis for this determination was, however, because sec. 6015(c) relief applies to assessed deficiencies. Sec. 6015(c)(1). The deficiency in petitioner’s case was only $15,479.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011