Lanny L. Christensen - Page 3

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          See Estate of Wenner v. Commissioner, supra at 286; see also                
          Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  While                     
          petitioner relies upon section 6015(e) in petitioning this Court            
          to decide whether he is entitled to any relief under section                
          66(c), we have previously held that section 6015(e) does not give           
          us jurisdiction to decide that issue.  See Bernal v.                        
          Commissioner, 120 T.C. 102 (2003).  While the Court does have               
          jurisdiction to decide a taxpayer’s claim for equitable relief              
          under section 66(c) in the setting of a so-called deficiency case           
          commenced under section 6213(a), see, e.g., id. at 107; Beck v.             
          Commissioner, T.C. Memo. 2001-198, this proceeding is not such a            
          case.                                                                       
               Petitioner also claims relief under section 6013(e).  Under            
          that section, before its repeal, a claim in this Court for relief           
          from joint liability was an affirmative defense in a deficiency             
          proceeding.  Section 6013(e) did not allow the Court to grant               
          relief to a taxpayer, such as petitioner, who filed a so-called             
          stand-alone petition; i.e., a petition not related to a                     
          deficiency proceeding.  See Goldin v. Commissioner, T.C. Memo.              
          2004-129; Brown v. Commissioner, T.C. Memo. 2002-187.  We lack              
          jurisdiction to grant petitioner relief under section 6013(e) for           
          any of the years 1989 through and 1992.                                     









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