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.
6015.
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