Mildred L. Jones - Page 6

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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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