- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011