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Conclusion
Petitioners are not entitled to relief under section 6015
with regard to the taxable year 1980 because their taxes for that
year were fully paid prior to the effective date of section 6015.
In addition, petitioner Scott P. Thurner is not entitled to
relief under section 6015 with regard to the taxable years 1981,
1990, and 1992 due to the application of the doctrine of res
judicata as set forth in section 6015(g)(2).
To reflect the foregoing,
An Order and Decision will be
entered in docket No. 3586-02
granting respondent’s Motion for
Summary Judgment, as supplemented,
and an appropriate Order will be
issued in docket No. 9971-01.
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Last modified: May 25, 2011