Yvonne E. Thurner - Page 18

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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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