- 3 - portion of her 1995 tax liability should be refunded to petitioner “based upon her meritorious claim for Innocent Spouse Relief.” By Final Notice of Determination dated January 29, 2002, respondent determined that petitioner was not entitled to relief from joint and several liability relating to 1994, 1995, or 1996. In response, on May 6, 2002, petitioner, while residing in Wildwood, Missouri, filed a petition pursuant to section 6015(e)(1) seeking review of respondent’s determination. On April 15, 2003, respondent determined that petitioner was entitled to relief from joint and several liability, pursuant to section 6015(b), relating to 1994 and, pursuant to section 6015(f), relating to 1995 and 1996. OPINION Petitioner contends, in essence, that the overpayment in issue relates to 1997 and, therefore, pursuant to section 6511(a), her refund claims were timely. Respondent contends that because respondent made no determination relating to 1997, the Court has no jurisdiction over that year. Respondent further contends that the overpayment in issue relates to 1995, and, therefore, petitioner is not entitled to a refund of her overpayment because her refund claims were made after thePage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011