Victoria Rae Moore - Page 9

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          preponderance of the evidence that she did not meaningfully                 
          participate in the prior proceedings.  Huynh v. Commissioner,               
          T.C. Memo. 2006-180; Monsour v. Commissioner, T.C. Memo. 2004-              
               A taxpayer who has filed a joint return may seek relief                
          from joint and several liability by following procedures                    
          established in section 6015.  Section 6015 may apply to a tax               
          liability that arose after July 22, 1998, and also to a tax                 
          liability that arose on or before such date and remained unpaid             
          as of July 22, 1998.  See Internal Revenue Service Restructuring            
          and Reform Act of 1998, Pub. L. 105-206, sec. 3201(g)(1), 112               
          Stat. 740; Vetrano v. Commissioner, 116 T.C. 272, 277 (2001).               
               The doctrine of res judicata provides that, when a court of            
          competent jurisdiction enters a final judgment in a cause of                
          action, the parties are bound “‘not only as to every matter which           
          was offered and received * * * but as to any other admissible               
          matter which might have been offered for that purpose.’”                    
          Commissioner v. Sunnen, 333 U.S. 591, 597 (1948) (quoting                   
          Cromwell v. County of Sac, 94 U.S. 351, 352 (1877)).  The                   
          doctrine also applies where the Court’s final decision was based            
          on an agreement between the parties.  See United States v.                  
          Bryant, 15 F.3d 756, 758 (8th Cir. 1994).                                   
               Section 6015(g)(2) provides that, in the case of an election           
          under section 6015(b) or (c) for any taxable year that is the               

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