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of determination denying, in part, her request for section 6015 relief.
Discussion
Jurisdiction
The Tax Court is a court of limited jurisdiction. Naftel v.
Commissioner, 85 T.C. 527, 529 (1985). Under section
6015(e)(1)(A), the Court has jurisdiction to review an
administrative determination regarding relief from joint and
several liability, or a claim for relief where the Commissioner
has failed to rule, as a “stand-alone” matter independent of any
deficiency proceeding where the Commissioner has asserted a
deficiency against the taxpayer. Billings v. Commissioner, 127
T.C. 7 (2006), on appeal (10th Cir., Oct. 23, 2006).
The Court has jurisdiction over this “stand-alone” matter
under section 6015(e)(1)(A) because respondent has asserted a
deficiency against petitioner for 2000. See sec. 6015(e)(1).
Section 6015(c) Relief
Generally, married taxpayers may elect to file a joint
Federal income tax return. Sec. 6013(a). After making the
election, each spouse is jointly and severally liable for the
entire tax due. Sec. 6013(d)(3). As a threshold matter,
petitioner argues that she is not liable for the deficiency
assessment, because she did not sign the joint return for 2000
that was filed with the Internal Revenue Service (IRS).
Petitioner contends that she never saw the return. She further
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