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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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Last modified: May 25, 2011