Edwina Diane Campbell - Page 1

                                   121 T.C. No. 16                                    

                               UNITED STATES TAX COURT                                

                        EDWINA DIANE CAMPBELL, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2604-02.              Filed November 24, 2003.              

                    By Final Notice of Determination dated Nov. 6,                    
               2001, R determined that P was not entitled to relief                   
               from joint and several liability relating to 1989                      
               because the request was, pursuant to sec. 6015, I.R.C.,                
               filed more than 2 years after R’s first collection                     
               activity against P.  On Feb. 1, 2002, P filed,                         
               pursuant to sec. 6015(e)(1), I.R.C., a petition seeking                
               review of R’s determination.  On Mar. 10, 2003, P                      
               filed a Motion for Partial Summary Judgment and on                     
               Mar. 31, 2003, R filed a Notice of Objection and                       
               Cross-Motion for Summary Judgment.  The issue in both                  
               parties’ motions is whether R’s application of P’s                     
               overpayment, relating to 1998, as a credit against P’s                 
               1989 tax liability is, pursuant to sec. 6015, I.R.C., a                
               collection activity that bars P’s request for relief                   
               relating to 1989.                                                      

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