Natalie W. McGee - Page 2

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               sec. 6015, I.R.C.  Internal Revenue Service Restructuring              
               and Reform Act of 1998 (RRA 1998), sec. 3501(b), Pub. L.               
               105-206, 112 Stat. 770.                                                
                    Held, further, It is inequitable and an abuse of                  
               discretion for R to apply the 2-year limitation period of              
               Rev. Proc. 2000-15, sec. 5, 2000-1 C.B. 447, 449, because              
               of R’s failure to send the notice required by RRA 1998                 
               sec. 3501(b).                                                          

               Natalie W. McGee, pro se.                                              
               Marshall R. Jones, for respondent.                                     


                                       OPINION                                        

               GOEKE, Judge:  The sole matter before the Court is whether             
          it was an abuse of discretion for respondent to deny petitioner’s           
          request for equitable relief from joint liability based on                  
          section 6015(f)1 solely because petitioner made her request more            
          than 2 years after respondent’s first collection activity.                  
               Petitioner challenges the application of the 2-year limit on           
          section 6015(f) requests imposed by Rev. Proc. 2000-15, sec. 5,             
          2000-1 C.B. 447, 449, when inadequate notice of collection                  
          activity was sent to her, and, as a result, she did not become              
          aware of her section 6015 rights until after the 2-year period              
          expired.                                                                    




               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code currently in effect.                              




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