- 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 NextLast modified: November 10, 2007