Connie Lucic, Petitioner, and Michael J. Lucic, Intervenor - Page 5




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          September 19, 2006, respondent contended that in light of                   
          Billings v. Commissioner, supra, the Court lacked jurisdiction              
          over this case.  Petitioner’s response contended that the Court             
          possessed the requisite authority to enter the stipulated                   
          decision in this case.  The Court received no response from                 
          intervenor.                                                                 
               In the Tax Relief and Health Care Act of 2006, Pub. L. 109-            
          432, div. C, sec. 408, 120 Stat. 3061, Congress reinstated our              
          jurisdiction to review the Commissioner’s determinations under              
          section 6015(f) with respect to tax liability remaining unpaid on           
          or after December 20, 2006.  By Order dated January 10, 2007, we            
          ordered the parties, including intervenor, to file responses                
          addressing the Court’s jurisdiction in this case.  In his                   
          response filed February 5, 2007, respondent indicated that                  
          petitioner’s liability for tax year 2000 remained unpaid as of              
          December 20, 2006, so that under the recent amendment to section            
          6015, this Court has jurisdiction over this case.  Similarly, in            
          her response filed January 9, 2007, petitioner maintained that              
          this Court has jurisdiction over this case.  The Court has                  
          received no response from intervenor.                                       
                                     Discussion                                       
               It is undisputed that petitioner’s liability for tax year              
          2000 remained unpaid as of December 20, 2006.  Accordingly,                 
          pursuant to the recent amendment to section 6015 by the Tax                 







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