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Ms. Peet with notice of this proceeding and her right to
intervene.4 She did not, however, file a notice of intervention
and did not appear nor participate in the trial of this case.
A taxpayer generally may petition this Court for a review of
the Commissioner’s determination denying relief under section
6015. Sec. 6015(e)(1)(A). On July 25, 2006, this Court issued
Billings v. Commissioner, 127 T.C. 7 (2006), holding that the
Court does not have jurisdiction to review the Commissioner’s
denial of relief under section 6015(f) in a stand-alone section
6015 case where no deficiency has been asserted. The Tax Relief
and Health Care Act of 2006, Pub. L. 109-432, div. C, sec. 408,
120 Stat. 3061, amended section 6015(e)(1) to provide that this
Court may review the Commissioner’s denial of relief under
section 6015(f) in cases where no deficiency has been asserted.5
Accordingly, this Court has jurisdiction to review respondent’s
determination that petitioner is not entitled to relief under
section 6015(f) from tax reported but not paid on his joint
income tax returns for 2000 and 2001.
4Between the time that the petition was filed in this case
and the time of trial, Ms. Peet was found in New Zealand,
extradited to the United States, and incarcerated. As of the
date of trial, petitioner’s minor son had been returned to the
United States and was in petitioner’s custody.
5The legislative amendment applies “with respect to
liability for taxes arising or remaining unpaid on or after the
date of the enactment of this Act.” The date of enactment was
Dec. 20, 2006. See Tax Relief and Health Care Act of 2006, Pub.
L. 109-432, div. C, sec. 408, 120 Stat. 3061.
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Last modified: May 25, 2011