Louise Sirianni - Page 4

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          brought under section 6404.  Respondent has not accused                     
          petitioner of any inappropriate practice, such as delay, bad                
          faith, or dilatory motive in amending the petition.  Further,               
          respondent has not shown that petitioner’s amendment would                  
          prejudice respondent in any respect.                                        
               Respondent moved for partial summary judgment on the                   
          question of whether we have jurisdiction to decide petitioner’s             
          section 6015 claim for relief from joint and several liability.             
          Respondent argues that we lack jurisdiction over the section 6015           
          claim because petitioner’s right to petition under section 6015             
          had not matured.  Respondent further argues that a claim for                
          section 6015 relief does not fit within our statutory                       
          jurisdiction to decide a section 6404 proceeding.                           
               Summary judgment is appropriate if there are no genuine                
          issues as to any material facts and a decision may be rendered as           
          a matter of law, whereas a partial summary adjudication may be              
          made which does not dispose of all the issues in the case.  Rule            
          121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520                  
          (1992), affd. 17 F.3d 965 (7th Cir. 1994).  There is no dispute             
          as to any material facts, and this controversy involves a                   
          question that is ripe for partial summary judgment.  See Fla.               
          Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988).                       
               “[T]he Tax Court is a court of limited jurisdiction, and we            

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