Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor - Page 2

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          1992, 1993, 1994, 1995, or 1996 (the years in issue).  Petitioner           
          petitioned this Court under section 6015(e)(1) and contends she             
          is eligible for relief under section 6015(f).  Petitioner’s                 
          former husband, Stanley Murray (intervenor), intervened and                 
          supports her claim.2  See Rule 325(b).  We hold that petitioner             
          is entitled to relief under section 6015(f) for the years in                
          issue.3                                                                     
               Based on Billings v. Commissioner, 127 T.C. 7 (2006), and              
          Commissioner v. Ewing, 439 F.3d 1009 (9th Cir. 2006), revg. 118             
          T.C. 494 (2002) and vacating 122 T.C. 32 (2004), we dismissed               
          this case for lack of jurisdiction by order dated October 2,                
          2006.    See also Bartman v. Commissioner, 446 F.3d 785 (8th Cir.           
          2006), affg. in part and vacating in part T.C. Memo. 2004-93.               
          However, Congress subsequently reinstated our jurisdiction to               
          review the Commissioner’s determinations under section 6015(f)              
          with respect to tax liability remaining unpaid on or after                  
          December 20, 2006.  Tax Relief and Health Care Act of 2006, Pub.            
          L. 109-432, div. C, sec. 408, 120 Stat. 3061.  The parties                  


               1(...continued)                                                        
          Court Rules of Practice and Procedure.                                      
               2  We previously held that Mr. Murray may intervene to                 
          support petitioner’s claim for relief.  Van Arsdalen v.                     
          Commissioner, 123 T.C. 135 (2004).                                          
               3  Respondent contends that we may consider only the                   
          administrative record in deciding this case.  See discussion                
          below at par. D, p. 20.                                                     




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