- 2 - to decide whether petitioner is entitled to relief pursuant to section 6015(f).1 Background Some of the facts have been stipulated. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time she filed the petition, petitioner resided in San Francisco, California. On or about January 20, 1999, petitioner filed a request for relief from joint and several liability for income taxes pursuant to section 6015(f) for 1995 and 1996. Petitioner admitted that relief is not available under section 6015(b) or (c) for 1995 and 1996. No deficiency was asserted against petitioner for 1995 or 1996. Discussion The Tax Court is a court of limited jurisdiction. Commissioner v. Ewing, 439 F.3d 1009, 1012 (9th Cir. 2006), revg. 118 T.C. 494 (2002). Whether this Court has jurisdiction is fundamental and may be raised by a party or on the Court’s own motion. Ewing v. Commissioner, 118 T.C. at 495; Fernandez v. Commissioner, 114 T.C. 324, 328 (2000). 1 Unless otherwise indicated, all section references are to the Internal Revenue Code. In her petition, petitioner sought relief pursuant to sec. 6015 for 1993, 1994, 1995, and 1996. The parties agree that 1993 and 1994 are not at issue in this case.Page: Previous 1 2 3 Next
Last modified: May 25, 2011