John William Hollis - Page 3

                                        - 2 -                                         
          entered is not reviewable by any court, and this opinion should             
          not be cited as authority.                                                  
               Respondent determined that petitioner is not entitled to               
          relief from joint liability for tax under section 6015(b), (c),             
          or (f) for 1999.  Petitioner filed a petition under section                 
          6015(e)(1) seeking review of respondent’s determination.                    
          Petitioner’s former wife (intervenor) filed a notice of                     
          intervention under Rule 325(b) and opposes such relief.                     
               Petitioner prepared and petitioner and intervenor signed and           
          filed a joint return for 1999 in which they correctly reported              
          the amount of tax but overstated their Federal income tax                   
          withholding by $2,000.  Respondent did not immediately discover             
          the error and issued a $1,491 refund to petitioner and intervenor           
          for 1999.  Petitioner alone benefited from the refund.                      
               The sole issue for decision is whether, under section                  
          6015(b), (c), or (f), petitioner is entitled to relief from                 
          repaying the erroneous refund for 1999.2  We hold that he is not.           









               2 We derive this statement of petitioner’s position from the           
          petition.  Petitioner also claims generally that he should be               
          relieved from joint and several liability for 1999.  However, he            
          has presented no argument for relief from liability other than              
          for the liability arising from the erroneous refund for 1999.               




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011