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to be conducted under the small tax case procedures of
sec. 7463, I.R.C.
Sheryl D. King Richards, for petitioner.
Kristina L. Rico, for respondent.
OPINION
RUWE, Judge: Petitioner timely filed a petition under
section 6015(e)1 seeking review of respondent’s final
determinations denying her relief from joint and several
liability under section 6015 for the tax years 1996, 1997, 1998,
1999, 2000, and 2002. Petitioner requested that this case be
conducted under section 7463, which provides for “small tax case”
or “S case” procedures. Section 7463 generally allows disputes
in small tax cases to be decided in proceedings in which the
normally applicable procedural and evidentiary rules are relaxed.
See Rule 174(b). This Opinion addresses respondent’s motion to
remove the small tax case designation (motion). In his motion,
respondent argues that this section 6015(e) “stand-alone” case
fails to qualify as a small tax case because the aggregate amount
of relief being sought exceeds the $50,000 limit provided in
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure. The Tax Relief and Health
Care Act of 2006, Pub. L. 109-432, div. C, sec. 408, 120 Stat.
3061, amended sec. 6015(e)(1) and applies to all liabilities for
taxes arising or remaining unpaid on or after Dec. 20, 2006, the
date of enactment, and thus applies here.
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Last modified: November 10, 2007