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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