- 5 - deficiency, and respondent assessed the tax deficiency and statutory additions. Thereafter, petitioner sought relief under section 6015. On February 11, 2003, respondent mailed to petitioner a final notice advising him that his requested section 6015 relief had been denied and that if he wished to contest this determination, he must file a petition with the U.S. Tax Court within 90 days. This Court’s jurisdiction to review petitioner’s claim for relief is conferred by section 6015(e), which allows a spouse who has requested relief from joint and several liability to contest the Commissioner’s denial of relief by filing a timely petition in this Court. Petitioner filed a timely petition with this Court on March 25, 2003. On May 22, 2003, respondent filed an answer to petitioner’s petition and a certification under Rule 325(b), as amplified by King v. Commissioner, 115 T.C. 118 (2000). The certification confirmed that respondent had notified Ms. Cullen that petitioner had filed a claim for relief from joint and several liability and that she could intervene. Despite the notice, Ms. Cullen has not intervened in this case. OPINION I. Contentions of the Parties Petitioner contends that he is eligible for relief from joint and several liability under section 6015(b), (c), or (f) for the 1999 tax liability and statutory additions. In essence,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011