- 4 - A taxpayer seeking relief from joint liability is seeking relief from amounts that have accrued with regard to the liability for which relief is sought, regardless of whether the ministerial act of assessment on those amounts has occurred. Thus, for purposes of section 7463(f)(1), it is appropriate to include unassessed interest and penalties that have accrued on amounts for which the taxpayer seeks relief when determining whether the amount of relief sought exceeds $50,000. Id. at __ (slip op. at 6-8). The record in this case shows that on the day petitioner filed her petition, the amount of relief sought, including interest and penalties, exceeded $50,000. Accordingly, we will deny petitioner’s Motion to Change Case to a “Small Tax Case”. The proceedings in this case will continue pursuant to the Court’s regular case procedures. To reflect the foregoing, An appropriate order will be issued.Page: Previous 1 2 3 4Last modified: November 10, 2007