- 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