- 10 - subject of a final court decision, such decision shall be conclusive unless the individual’s qualification for relief was not an issue in the prior court proceeding and the individual did not “participate meaningfully” in the prior proceeding. In Vetrano v. Commissioner, supra at 278, we explained that an individual who participated meaningfully in a court proceeding is precluded from electing relief under section 6015(b) or (c) for the same taxable year after the decision of the court becomes final, whether or not the individual's qualification for relief under section 6015(b) or (c) was an issue in the prior proceeding. * * * Petitioner argues that her level of involvement in the prior case was not “meaningful” for purposes of section 6015(g)(2) because she: (1) Was not well informed about section 6015 relief, (2) was, at times, represented by counsel who were representing a large group of taxpayers; and (3) she followed Mr. Moore’s advice to settle. In effect, petitioner contends that she was not involved in discussions about and/or that she was not knowledgeable about law or procedure. Section 1.6015-1(e), Income Tax Regs., provides: (e) Res judicata and collateral estoppel.--A requesting spouse is barred from relief from joint and several liability under section 6015 by res judicata for any tax year for which a court of competent jurisdiction has rendered a final decision on the requesting spouse's tax liability if relief under section 6015 was at issue in the prior proceeding, or if the requesting spouse meaningfully participated in that proceeding and could have raised relief under section 6015. A requesting spouse has not meaningfully participated in a prior proceeding if, due to thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007