- 6 - The Court entered a decision on May 16, 2003, in docket No. 9654-02L, pursuant to a stipulation between petitioner and respondent, relating to the collection of petitioner’s income tax liabilities for 1995, 1996, 1997. Request for Innocent Spouse Relief Respondent received from petitioner on June 3, 2002, a Form 8857, Request for Innocent Spouse Relief, in which petitioner requested relief from joint and several liability under section 6015(c) and (f) for 1995, 1996, and 1997. A Notice of Determination Concerning Your Request for Relief from Joint and Several Liability under Section 6015 (notice of determination) denying petitioner’s request was issued to petitioner on January 12, 2005. Present Proceeding On April 18, 2005, petitioner filed with the Court a petition seeking a review of the notice of determination denying her request for relief from joint and several liability under section 6015 for 1995, 1996, and 1997. Respondent filed a motion to file answer out of time to allege the application of res judicata under section 6015(g)(2) for 1995 and 1996. Petitioner filed an objection, and respondent filed a response to petitioners’s objection. A hearing was held, and the Court granted respondent’s motion to file an answer out of time to allege the application of section 6015(g)(2).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007