Gilda A. Petrane - Page 2




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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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