- 5 - 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).Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011