- 2 - signed precludes her assertion of a claim for relief under sec. 6015, I.R.C. R also argues that the doctrines of res judicata and collateral estoppel preclude her assertion of a claim for relief under that section. Held: P is not precluded from claiming sec. 6015, I.R.C., relief because of her closing agreement. Sec. 6015, I.R.C., was enacted in 1998 in order to provide additional relief to taxpayers who had filed joint income tax returns. Sec. 6015, I.R.C., was made applicable to any tax remaining unpaid as of July 22, 1998. P signed the closing agreement in 1988, 10 years before the enactment of sec. 6015, I.R.C. Thus, when P signed the closing agreement, she never had the opportunity to request relief under sec. 6015, I.R.C., with regard to her 1982 and 1983 joint and several tax liabilities. Held, further, the doctrines of res judicata and collateral estoppel do not preclude P’s claim for sec. 6015, I.R.C., relief. Sandra G. Scott, for petitioner. Thomas M. Rohall, for respondent. RUWE, Judge: The issue for decision is whether a closing agreement entered into under section 71211 precludes the assertion of a claim for relief from joint and several liability under section 6015 where petitioner signed the closing agreement before the effective date of section 6015. We hold that it does not. 1Unless otherwise indicated, all section references are to the Internal Revenue Code as amended.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011