Ranie M. Raymond - Page 6




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          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...)           





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