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6015(f), petitioner should move this Court to amend her petition
to assert that specific allegation. Respondent, of course, would
then be given an opportunity to challenge petitioner’s motion.
Pursuant to the plain statutory language contained in
section 6015, our jurisdiction in a “stand alone” case brought
pursuant to section 6015(e) is limited to reviewing respondent’s
denial of relief from an existing joint and several tax liability
under subsections (b), (c), and (f) of section 6015. The
timeliness of the assessment of the underlying liability is not
an independent ground for relief under section 6015. We have no
jurisdiction over the issue petitioner wants to raise in her
proposed amendment to the petition. Accordingly, her motion for
leave to amend her petition is denied.
An appropriate order denying
petitioner’s motion for leave to
amend her petition will be issued.
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Last modified: May 25, 2011