- 3 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011