- 4 - I.R.C. � 6015(f) when respondent has not determined a deficiency. * * * In petitioner’s response, petitioner concedes that no tax liability remains unpaid as of December 20, 2006. Accordingly, Petitioner concedes that she is not seeking to invoke this Court’s juris- diction under �6015(e)(1) as amended by the Tax Relief and Health Care Act of 2006. She is seeking jurisdic- tions [sic] under [section] 6015(e)(1) prior to amend- ment. In petitioner’s response, petitioner points out that the United States Court of Appeals for the Second Circuit, where an appeal in the instant case would normally lie, has not addressed the issue of whether this Court has jurisdiction under section 6015(e)(1) prior to its amendment by the Act where a deficiency has not been asserted. Petitioner seems to suggest in peti- tioner’s response that, because the United States Court of Appeals for the Second Circuit has not addressed that issue, the Court should revisit and overrule its holding in Billings v. Commissioner, 127 T.C. 7 (2006). We held in Billings v. Commissioner, supra, that we lack jurisdiction under section 6015(e)(1) prior to its amendment by the Act to review a determination by the Commissioner denying relief under section 6015(f) where a deficiency has not been asserted. The Court is bound by the holding in Billings and declines any invitation by petitioner to revisit and overrule that holding.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011