- 2 - 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.Page: Previous 1 2 3 4 NextLast modified: November 10, 2007