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her 1992 income tax liability. Respondent determined that
petitioner remained liable for the remaining $1,801 of the
$5,3866 liability for 1992.
Form 2866, Certificate of Official Record, showed
petitioner’s account balance for 1992, as of March 21, 2002, as
$5,385.56. This was based on a tax assessment of $7,058, a
penalty assessment of $823, an interest assessment of $2,684.48,
fees and costs of $10, a $1,921.62 credit applied on April 15,
1999, a $3,268 credit applied on April 15, 2000, a $1,801 credit
applied on April 15, 2001, and a credit reversal of $1,801
applied on April 15, 2001.
OPINION
Petitioner does not dispute respondent’s determination that
she is entitled to partial relief pursuant to section 6015(f).
Petitioner essentially argues that, in light of respondent’s
granting partial section 6015(f) relief, respondent has not
correctly credited her account for 1992 and that she is due a
refund. Respondent argues that the Court does not have
jurisdiction to determine whether respondent properly credited
petitioner’s payments to her account or whether petitioner is
entitled to a refund to the extent attributable to his
determination that petitioner is entitled to section 6015(f)
relief. Respondent is mistaken.
6 This amount included interest.
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