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Notice 98-61, 1998-2 C.B. 756; Rev. Proc. 2000-15, 2000-1 C.B.
447; secs. 1.66-1 through 1.66-5, Proposed Income Tax Regs., 67
Fed. Reg. 2841 (Jan. 22, 2002). Rev. Proc. 2000-15, supra, also
provides that the taxpayer seeking equitable relief under section
66(c) must file Form 8857 or other similar statement signed under
penalties of perjury within 2 years of the first collection
activity against the requesting spouse. Under section 1.66-
4(g)(1), Proposed Income Tax Regs., supra, the requesting spouse
must file Form 8857 or other written request, signed under
penalties of perjury, indicating why such relief is appropriate
within the time period prescribed in paragraph (g)(2) of section
1.66-4, Proposed Income Tax Regs., supra.
The Tax Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent authorized by
Congress. Sec. 7442; Judge v. Commissioner, 88 T.C. 1175, 1180-
1181 (1987); Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
In a deficiency proceeding we may review a taxpayer’s
request for relief under section 66(c). In such circumstance, we
must decide whether the Commissioner abused his discretion. See
Hardy v. Commissioner, supra; Morris v. Commissioner, T.C. Memo.
2002-17; Beck v. Commissioner, T.C. Memo. 2001-198. The Court
6(...continued)
relief from joint and several liability on joint returns are
inapplicable. See Raymond v. Commissioner, 119 T.C. 191, 195-196
(2002).
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