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Commissioner, 114 T.C. 354, 363-364 (2000). As relevant in this
case, a person may file a so-called stand alone petition seeking
relief from joint and several liability on a joint return in
response to the Commissioner’s final notice disallowing a claim
for relief. See sec. 6015(e)(1); Mora v. Commissioner, 117 T.C.
279 (2001). Such a petition must be filed within 90 days of the
date that the Commissioner mailed the final notice disallowing
relief. Sec. 6015(e)(1)(A).
Analysis
The record in this case reflects that respondent issued a
final notice to petitioner disallowing her claim for relief from
joint and several liability for 1997 and 1998 in August 2001.
Petitioner did not file, however, a petition with the Court
challenging respondent’s determination. Petitioner does not
allege that the final notice was not mailed to her correct
address. In any event, the 90-day period in which petitioner
could have invoked this Court’s jurisdiction under section
6015(e) has long since expired.
Under the circumstances, we conclude that the Appeals Office
correctly determined that section 6330(c)(4) barred petitioner
from attempting to resurrect her claim for relief under section
6015 during her collection review hearing initiated under section
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Last modified: May 25, 2011