- 18 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011