- 6 - fact that her wages were garnished for prior-year joint liabilities before she signed the 1998 and 1999 returns.” Ms. Neidermeyer recommended that petitioner be denied equitable relief under section 6015(f). On August 12, 2004, respondent issued petitioner a notice of determination denying her request for equitable relief under section 6015(f). On November 15, 2004, petitioner filed her petition with this Court. Petitioner contended that respondent abused his discretion in denying her equitable relief under section 6015(f). This case was called for trial on March 27, 2006. On July 25, 2006, this Court issued Billings v. Commissioner, 127 T.C. 7 (2006), holding that the Court does not have jurisdiction to review the Commissioner’s denial of relief under section 6015(f) in a case where no deficiency has been asserted. Our holding in Billings was in accord with the Courts of Appeal opinions in Bartman v. Commissioner, 446 F.3d 785 (8th Cir. 2006), affg. in part and vacating T.C. Memo. 2004-93, and Commissioner v. Ewing, 439 F.3d 1009 (9th Cir. 2006), revg. 118 T.C. 494 (2002). On September 1, 2006, respondent filed a motion to dismiss for lack of jurisdiction contending that, in light of Billings v. Commissioner, supra, the Court lacked jurisdiction over this case. In the Tax Relief and Health Care Act of 2006, Pub. L. 109- 432, div. C, sec. 408, 120 Stat. 3061, Congress reinstated ourPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007