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Petitioner and her spouse jointly filed a Federal income tax
return (return) for each of their taxable years 1997 (1997
return), 2000 (2000 return), and 2003 (2003 return). Each of
those returns showed tax due. Petitioner and her spouse did not
pay the tax due shown in the 1997 return, the 2000 return, or the
2003 return.
Respondent has not asserted a deficiency for any of peti-
tioner’s taxable years 1997, 2000, and 2003.
On April 4, 2005, respondent received from petitioner Form
8857, Request for Innocent Spouse Relief (and Separation of
Liability and Equitable Relief), in which she requested relief
under section 6015.1
On January 19, 2006, respondent issued to petitioner a
notice of determination in which respondent denied her relief
under section 6015 with respect to her taxable years 1997, 2000,
and 2003. Petitioner timely filed a petition in the Court with
respect to that notice.
On January 10, 2007, the Court issued an Order (Court’s
January 10, 2007 Order), in which the Court directed each party
to file a response to that Order addressing the Court’s jurisdic-
tion over the instant case in light of the amendment to section
6015(e)(1) made by the Tax Relief and Health Care Act of 2006
1All section references are to the Internal Revenue Code in
effect at all relevant times.
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Last modified: May 25, 2011