T.C. Summary Opinion 2007-36
UNITED STATES TAX COURT
LOIS LIPTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12588-04S. Filed March 7, 2007.
Lois Lipton, pro se.
Kathleen Raup, for respondent.
GOLDBERG, Special Trial Judge: This is a case arising under
section 6015(f), as amended,1 and 7463 of the Internal Revenue
1 The Tax Relief and Health Care Act of 2006, Pub. L. 109-
432, 120 Stat. 2922, amended sec. 6015(e)(1) to provide that this
Court may review the Commissioner’s denial of relief under sec.
6015(f) in cases where no deficiency has been asserted. The
amendment applies “with respect to liability for taxes arising or
remaining unpaid on or after the date of the enactment” of the
Act, December 20, 2006. See Tax Relief and Health Care Act of
2006, Pub. L. 109-432, div. C. sec. 408, 120 Stat. 3062. As of
the date of enactment, there remained an unpaid liability for tax
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