Ranie M. Raymond - Page 1

                                   119 T.C. No. 11                                    

                               UNITED STATES TAX COURT                                

                           RANIE M. RAYMOND, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2354-01L.             Filed October 22, 2002.               

                    On her 1991 tax return, P’s filing status was                     
               listed as “Married filing separate return”.  On Jan. 9,                
               2001, R sent P a Notice of Determination Concerning                    
               Collection Action(s) Under Section 6320 and/or 6330                    
               regarding the 1991 tax year in which R determined that                 
               P was not entitled to raise a spousal defense because                  
               she did not file a joint return.  On Feb. 12, 2001, P                  
               sent to the Tax Court a Petition for Lien or Levy                      
               Action Under Code Section 6320(c) or 6330(d).  R filed                 
               a Motion for Partial Summary Judgment on the issue of                  
               whether P is eligible for relief under I.R.C. sec.                     
                    Held:  The petition was timely filed in order for                 
               the Court to have jurisdiction to review R’s denial of                 
               spousal relief.  Sec. 6015(e)(1), I.R.C.                               
                    Held, further, R’s Motion for Partial Summary                     
               Judgment is granted because there is no genuine issue                  
               as to whether P is entitled to relief under I.R.C. sec.                

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Last modified: May 25, 2011