Teri Geisen Rooks - Page 6

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               Section 6015(g) governs the allowance of credits and refunds           
          in cases where a taxpayer is granted relief pursuant to section             
          6015.  Section 6015(g)(1) provides:  “Except as provided in                 
          paragraphs (2) and (3), notwithstanding any other law or rule of            
          law (other than section 6511, 6512(b), 7121, or 7122), credit or            
          refund shall be allowed or made to the extent attributable to the           
          application of this section.”  Accordingly, we shall proceed to             
          determine the proper amount owed by, or to, petitioner pursuant             
          to section 6015(g).  See Washington v. Commissioner, 120 T.C. 137           
          (2003); see also Bartman v. Commissioner, T.C. Memo. 2004-93                
          (determining the effect of the Commissioner’s crediting, pursuant           
          to section 6402(a), the taxpayer’s overpayment for 1997 to the              
          liability for 1995 when the Commissioner determined the taxpayer            
          was entitled to relief pursuant to section 6015(f) for 1995).               
               Section 6511 requires that a claim for refund or credit of             
          an overpayment of any tax in respect of which the taxpayer is               
          required to file a return must be filed within 3 years from the             
          time the return was filed or 2 years from the time the tax was              
          paid, whichever of the periods expires later.  Washington v.                
          Commissioner, supra at 160.  On March 14, 2001, petitioner filed            
          her request for section 6015 relief.  This request encompasses a            
          refund request.  Id. at 162; see Bartman v. Commissioner, supra.            
          Respondent made his earliest refund offset to petitioner’s 1992             








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