- 6 -
section, we have jurisdiction to review respondent’s
determination as to section 6015 relief because petitioner filed
her petition within 90 days of the notice of determination.5
4(...continued)
(i) at any time after the earlier of--
(I) the date the Secretary
mails, by certified or registered
mail to the taxpayer’s last known
address, 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).
5 See sec. 301.6330-1(f)(2), Proced. & Admin. Regs. This
regulation provides:
Q-F2. With respect to the relief available to the
taxpayer under section 6015, what is the time frame
within which a taxpayer may seek Tax Court review of
Appeals’ determination following a CDP hearing?
A-F2. If the taxpayer seeks Tax Court review not only
of Appeals’ denial of relief under section 6015, but
also of relief with respect to other issues raised in
the CDP hearing, the taxpayer should request Tax Court
review within the 30-day period commencing the day
after the date of the Notice of Determination. If the
taxpayer only seeks Tax Court review of Appeals’ denial
of relief under section 6015, the taxpayer should
request review by the Tax Court, as provided by section
6015(e), within 90 days of Appeals’ determination. If
a request for Tax Court review is filed after the 30-
day period for seeking judicial review under section
6330, then only the taxpayer’s section 6015 claims may
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011