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Panuthos, as modified in major respects, are set forth below as
the report of the Court.
This case arose from petitioner’s request for relief from
joint and several liability under section 6015(f) for the taxable
years 1998, 1999, and 2000.2 After our Opinion was filed in
Billings, we issued an order directing the parties to show cause
why this case should not be dismissed for lack of jurisdiction.
Respondent filed a response to the Court’s order agreeing that we
lack jurisdiction. Petitioner filed a document that was
nonresponsive to the jurisdictional issue but questioned whether
she had any liability if no deficiency was asserted against her.
We have concluded that we lack jurisdiction to review
respondent’s denial of relief under section 6015(f) where no
deficiency has been asserted, and we shall therefore dismiss this
case for lack of jurisdiction.
Background
Some of the facts have been stipulated, and the stipulated
facts are incorporated by this reference. Petitioner and
2 Petitioner elected small tax case status pursuant to sec.
7463, and the Court granted the request. Before trial,
respondent made an oral motion to discontinue small tax case
proceedings because the amount of relief sought exceeded the
applicable jurisdictional amount prescribed in the statute. The
Court agreed with respondent and granted respondent’s oral motion
to strike the “S” designation from this case. See secs. 6015(e),
7463(f). The Court explained to the parties that the case would
be considered under the Rule 183 procedures.
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Last modified: May 25, 2011