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encompasses a review of the Commissioner’s determination with
respect to relief afforded by section 6015(c). Fernandez v.
Commissioner, 114 T.C. 324, 331 (2000). Thus, this Court has
jurisdiction to review the Commissioner’s determination that no
refund is due to a taxpayer under section 6015(g)(3).
Section 6015(c) is the basis upon which relief was granted
to petitioner. Section 6015(g) provides generally for the
allowance of credits and refunds in certain situations where
relief from joint liability is granted under section 6015.
However, section 6015(g)(3) states that no refund or credit shall
be allowed as a result of an election for relief under subsection
(c), and where the relief is granted pursuant to subsection (c).
The record shows that petitioner was not entitled to relief under
section 6015(b) because she had constructive knowledge of income
that was reported on the 1995 and 1996 joint returns, nor was she
entitled to any other relief except under section 6015(c).4
Petitioner argues that she is entitled to a refund because,
although she was told that filing delinquent returns was a
necessary predicate to consideration of collection alternatives,
the IRS did not suggest that she first request relief under
4Petitioner would be eligible for relief under sec. 6015(f)
only if it were shown that, contrary to respondent’s
determination, petitioner is not entitled to relief under sec.
6015(c). Sec. 6015(f)(2).
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Last modified: May 25, 2011