- 13 - 6. On July 19, 2006, respondent’s Appeals Officer requested a full abatement of the entire tax liability assessed against petitioners for the taxable year 2001. 7. Petitioner Cindy Chou’s claim for relief from joint and several liability under I.R.C. sec. 6015(f) for the taxable year 2001 is moot, as respondent has requested an abatement of all tax owed by petitioners for the taxable year 2001. 8. The only issue remaining in this case concerns whether Petitioner Cindy Chou is entitled to relief from joint and several liability under I.R.C. sec. 6015(f) for the taxable year 2000. 9. Because a Notice of Determination was not issued for a Collection Due Process appeal with respect to the taxable year 2000, I.R.C. secs. 6320 and 6330 do not provide the Court with jurisdiction to hear an appeal of Petitioner Cindy Chou’s claim for relief under I.R.C. sec. 6015(f) for the taxable year 2000. Thus, the only basis for the Tax Court to review respondent’s section 6015(f) determination in this case is section 6015(e). Respondent’s motion for continuance was based on then-outstanding caselaw to the effect that the Court would not have jurisdiction to hear Mrs. Chou’s section 6015(f) claim because no deficiency had been determined. (Respondent now concedes jurisdiction over that issue based on subsequently enacted legislation, as discussed below.) Petitioners objected to respondent’s motion for continuance. Petitioners also objected to respondent’s abatement of the assessment for 2001, accusing respondent of attempting to deprive the Court of jurisdiction over that year. Respondent’s motion for continuance was denied.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: November 10, 2007