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Warren N. Nemiroff, for petitioner.
Valerie L. Makarewicz, for respondent.
OPINION
GERBER, Chief Judge:1 Respondent issued a notice of
determination to petitioner denying her request for relief under
section 60152 and specifically finding that she was ineligible
for relief under section 6015(b), (c), or (f). Petitioner filed
a petition with this Court seeking relief from joint and several
liability. On October 12, 2004, respondent filed a motion for
summary judgment.
At the hearing, relying on our holding in McGee v.
Commissioner, 123 T.C. 314 (2004), respondent moved to withdraw
his summary judgment motion, and the Court granted respondent’s
motion to withdraw. Concurrent with respondent’s motion to
withdraw, respondent filed a motion for remand, which the Court
took under advisement. The motion for remand requests the Court
to remand the case to respondent’s Cincinnati Centralized
Innocent Spouse Operation Unit for consideration of petitioner’s
claim for relief, under section 6015, from a 1995 tax liability.
1 This case was reassigned from Special Trial Judge Dean to
Chief Judge Gerber by an order dated Mar. 10, 2005.
2 Unless otherwise indicated, section references are to
sections of the Internal Revenue Code, as amended.
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Last modified: May 25, 2011