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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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Last modified: November 10, 2007