- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007