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in a deficiency proceeding. Corson v. Commissioner, 114 T.C.
354, 358 (2000); Goldin v. Commissioner, T.C. Memo. 2004-129;
Brown v. Commissioner, T.C. Memo. 2002-187. There is no
provision in the Internal Revenue Code which allows us to grant
relief under the former section 6013(e) to a taxpayer who filed a
“stand alone” petition under section 6015.3 Goldin v.
Commissioner, supra; Brown v. Commissioner, supra. While section
6015(e) vests the Court with jurisdiction to review an election
for relief from joint and several liability arising from a stand
alone petition, there is no equivalent provision under the former
section 6013(e). See sec. 6015(e); Brown v. Commissioner, supra.
For the reasons described above, petitioner is not entitled
to relief from joint and several liability for 1994 and 1995
under either section 6015 or its predecessor section 6013(e).
3 A so-called stand alone petition permits the Court to
review an administrative determination regarding relief from
joint and several liability independent of any other proceeding
(such as a deficiency proceeding or a review of a lien or levy
action).
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Last modified: May 25, 2011