- 2 -
of section 7463(b), the decision to be entered is not reviewable
by any other court, and this opinion shall not be treated as
precedent for any other case.
This case arises from a request for innocent spouse relief
under section 6015(f) with respect to petitioner’s 1998 and 1999
taxable years. No notice of deficiency was issued for either of
these years. Petitioner requested relief by filing Form 8857,
Request for Innocent Spouse Relief, for the years 1997, 1998, and
1999. In her application, petitioner sought relief under section
6015(f) and specifically stated she was not seeking relief under
section 6015(b) or (c). Respondent determined that petitioner
was not entitled to relief under section 6015(f); thus, the issue
is whether respondent’s denial of relief under section 6015(f)
was an abuse of discretion with respect to petitioner’s taxable
years 1998 and 1999.3
Background
The facts may be summarized as follows. At the time the
petition was filed petitioner resided in Temple, Pennsylvania.
2(...continued)
Internal Revenue Code as amended, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
3 The record is unclear as to the status of petitioner’s
request for relief for taxable year 1997. Neither the
preliminary determination letter nor the notice of determination
addressed any request for relief for taxable year 1997.
Moreover, in her petition to this Court, petitioner only
requested a review of the denial of relief for taxable years 1998
and 1999. The year 1997, therefore, is not before the Court.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: November 10, 2007