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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.
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