Kathleen Sullivan Alioto - Page 2

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          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.             






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