Judith E. Schmick - Page 2




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          final determination denying her relief from joint and several               
          liability under section 6015 for the tax years 1997, 1999, 2000,            
          2001, and 2002.  On October 11, 2006, petitioner filed a Motion             
          to Change Case to a “Small Tax Case”.  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).  Section 7463(f)(1) authorizes use           
          of the small tax case procedures “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”.  By Order dated November            
          30, 2006, this Court directed petitioner to file, on or before              
          December 21, 2006, a supplement to her motion filed October 11,             
          2006, setting forth whether the amount of relief sought in this             
          case exceeds the $50,000 limit under section 7463(f)(1).                    
          Petitioner failed to timely respond to the Court’s Order, and the           
          Court denied her Motion to Change Case to a “Small Tax Case” on             
          January 12, 2007.                                                           
               On February 8, 2007, petitioner filed another Motion to                
          Change Case to a “Small Tax Case”.  Petitioner attached a copy of           
          Form 8857, Request for Innocent Spouse Relief, that she submitted           
          on February 24, 2006.  On the Form 8857, she explained:  “We are            
          asking for relief for the following amounts” listed as follows:             

               1(...continued)                                                        
          Dec. 20, 2006, the date of the enactment, and thus it applies               
          here.                                                                       






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