Kathryn Bernal - Page 1

                                   120 T.C. No. 6                                     

                               UNITED STATES TAX COURT                                

                            KATHRYN BERNAL, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 930-02.               Filed February 20, 2003.              

                    P filed individual Federal income tax returns as                  
               married, filing separate, for the taxable years 1993,                  
               1994, 1995, and 1996.  During these years, P was                       
               married and was domiciled in California, a community                   
               property State.  R issued notices of deficiency for the                
               years involved, and a timely petition was not filed.  P                
               later made a request for relief from tax on community                  
               property income pursuant to sec. 66(c), I.R.C.  R                      
               issued a notice of determination denying the request                   
               for relief.  P filed a petition seeking review of R’s                  
               determination.  R moved to dismiss for lack of                         
                    Held:  Unlike sec. 6015(e), I.R.C., sec. 66,                      
               I.R.C. (Treatment of Community Property Income), does                  
               not provide for jurisdiction permitting a taxpayer to                  
               file a “stand alone” petition in response to a denial                  
               of a request for relief made pursuant to sec. 66(c),                   
               I.R.C.  Since we are without jurisdiction to review the                
               denial of the request for relief herein, and P did not                 
               file a timely petition in response to the notices of                   

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