Annette D. Goode-Parker - Page 7

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               The Commissioner then revisited Ms. Goode-Parker’s case to             
          decide it on the merits, but again rejected it.  He denied relief           
          under section 6015(b) and (c) because he found that she had                 
          reason to know of the items causing the understatement of tax.              
          And he also denied relief under section 6015(f) because he found            
          that she did not reasonably believe, when she signed the return,            
          that the tax would be paid in a reasonable amount of time;                  
          because she did not establish that paying the tax would cause her           
          economic hardship; and because a portion of the unpaid tax was              
          attributable to her.                                                        
               Ms. Goode-Parker seeks review of this revised determination.           
          Trial was held in Los Angeles, and she resided in California when           
          she filed her petition.                                                     
               This is one of a large number of cases affected first by the           
          Ninth Circuit’s opinion in Commissioner v. Ewing, 439 F.3d 1009             
          (9th Cir. 2006), revg. 118 T.C. 494 (2002), vacating 122 T.C. 32            
          (2004), and then by this Court’s opinion in Billings v.                     
          Commissioner, 127 T.C. 7 (2006).  These cases both held that the            
          Tax Court’s jurisdiction to review the Commissioner’s innocent              
          spouse determinations requires that a deficiency have been                  
          asserted against the taxpayer seeking relief.  To understand what           
          this means requires a little background:  Section 6013(a) lets              
          married couples choose to file their Federal tax return jointly,            

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