Carol J. Hunter - Page 2

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          filed in response to a determination concerning relief from joint           
          and several liability under section 6015.1  The issue for                   
          decision is whether the Tax Court has jurisdiction under section            
          6015(e) to review the Commissioner’s determination that                     
          petitioner is not entitled to relief.                                       
                                     Background                                       
               Petitioner was formerly married to William B. Hunter III               
          (Mr. Hunter).  Petitioner and Mr. Hunter filed joint Forms 1040,            
          U.S. Individual Income Tax Return, for 1996, 1997, and 1998.                
          Each of these returns reflected a balance due and was not                   
          accompanied by full payment.                                                
               In July of 2003, the Internal Revenue Service (IRS) received           
          from petitioner a Form 8857, Request for Innocent Spouse Relief.            
          Petitioner sought relief for underpayments of tax for, inter                
          alia, 1996 through 1998 under section 6015(f).  On July 28, 2005,           
          the IRS issued to petitioner a notice of determination denying              
          her request for section 6015 relief.  Petitioner filed a                    
          petition, and subsequent amended petition, with this Court                  
          contesting the adverse determination.  At the time these                    
          documents were filed, petitioner resided in New Mexico.  The case           
          is presently calendared for trial at the session of the Court               
          commencing on November 27, 2006, in Albuquerque, New Mexico.                



               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code of 1986, as amended.                                  




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