129 T.C. No. 1
UNITED STATES TAX COURT
GILDA A. PETRANE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2011-07. Filed July 24, 2007.
P filed a petition pursuant to sec. 6015(e),
I.R.C., seeking relief from R’s determination to deny
spousal relief from unpaid joint tax liabilities for
the years 1996-2000 and 2002. P requested that her
case be conducted under the small tax case procedures
authorized by sec. 7463(f)(1), I.R.C., “in the case of
* * * a petition to the Tax Court under section 6015(e)
in which the amount of relief sought does not exceed
$50,000”. On the date the petition was filed, the
amount of unpaid tax, interest, and penalties for which
P sought relief did not exceed $50,000 for any single
year, but the total of those amounts for all years
exceeded $50,000.
Held: The amount of relief sought for purposes of
sec. 7463(f)(1), I.R.C., includes the total amount of
tax, interest, and penalties, including accrued but
unassessed interest and penalties, for which relief is
sought in the petition calculated as of the date the
petition is filed. The total amount of relief P seeks
exceeds $50,000. Therefore, this case is not eligible
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