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of the parties, we hold that Ms. Skoller is entitled to separate
tax liability under section 6015(c).6
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered
under Rule 155.
6 We need not rule on Ms. Skoller’s claim for relief under
sec. 6015(f). Sec. 6015(f) is available only if “relief is not
available * * * under subsection (b) or (c).” Sec. 6015(f)(2).
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Last modified: May 25, 2011