- 2 -
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 Matthew A. McCausland
(Mr. McCausland). Petitioner and Mr. McCausland filed a joint
Federal income tax return for 2002. The return reflected a
balance due and was not accompanied by full payment.
In July of 2004, the Internal Revenue Service (IRS) received
from petitioner a Form 8857, Request for Innocent Spouse Relief.
Petitioner sought relief for an underpayment of tax for 2002
under section 6015(f). On January 13, 2005, the IRS issued to
petitioner a notice of determination denying her request for
section 6015 relief. Petitioner filed a petition with this Court
contesting the adverse determination. At the time the petition
was filed, petitioner provided an address 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.
Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011