- 2 - 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.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011