Helena Anne Phillipson - Page 5

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          aforementioned provisions.  As a general rule, taxpayers who                
          qualify for relief under section 6015(b) or (f), but not section            
          6015(c), are entitled to a refund or credit attributable to the             
          application of section 6015.  Sec. 6015(g)(1), (3).  After a                
          taxpayer requests relief under section 6015, the taxpayer may               
          petition this Court for a review of the Commissioner’s subsequent           
          determination.  Sec. 6015(e)(1)(A).  This Court’s jurisdiction              
          in cases brought under section 6015(e)(1) encompasses a review of           
          the Commissioner’s determination with respect to relief afforded            
          by section 6015(c).  Fernandez v. Commissioner, 114 T.C. 324, 331           
          (2000).  Thus, this Court has jurisdiction to review the                    
          Commissioner’s determination that no refund is due to a taxpayer            
          under section 6015(g)(3).                                                   
               Section 6015(c) is the basis for the relief that was granted           
          to petitioner.  Section 6015(g) provides generally for the                  
          allowance of credits and refunds in certain situations where                
          relief from joint liability is granted under section 6015.                  
          However, section 6015(g)(3) states that no refund or credit shall           
          be allowed as a result of an election under subsection (c), and             
          the relief to petitioner was granted under subsection (c).  The             
          record shows that petitioner was not entitled to relief under               
          section 6015(b) because petitioner had constructive knowledge of            









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