- 2 - Donald R. Williams, for petitioner. Audrey M. Morris, for respondent. MEMORANDUM OPINION NIMS, Judge: Respondent determined that petitioner is not entitled to relief from joint and several liability for tax under section 6015(f) for 1986 and 1987. Petitioner filed a petition under section 6015(e)(1) seeking review of respondent’s determination. The parties agree that petitioner would be eligible for relief under section 6015(f) if refund or credit of a resulting overpayment were not statutorily barred. The issue for decision is therefore whether such refund or credit is available to petitioner for her taxable years 1986 and 1987. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. This case was submitted fully stipulated pursuant to Rule 122, and the facts are so found. The stipulations of the parties, with accompanying exhibits, are incorporated herein by this reference. Background At the time the petition was filed in this case, petitioner resided in Kerrville, Texas.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011