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relief for the reasons that the tax liability was associated with
income exclusively derived from petitioner’s employment, and that
there was no evidence of marital abuse or economic hardship.
Petitioner argues in her petition that she is entitled to
relief from joint and several liability under section 6015(f).
The petition enumerates two arguments: first, that but for Mr.
Poe’s inability and/or refusal to find steady employment,
petitioner would not have had to resort to cashing in her IRA
account to support their family through the worst of times, and
second, that their divorce decree specifies, with respect to
taxable year 2002, that she and Mr. Poe would each be liable for
nevermore than 50 percent of the tax due. Pursuant to Rule 325
and King v. Commissioner, 115 T.C. 118 (2000), respondent served
Mr. Poe with notice of this proceeding and his right to
intervene. He did not, however, file a notice of intervention
and did not appear or otherwise participate in this case.
A taxpayer generally may petition this Court for review of
the Commissioner’s determination denying relief under section
6015. Sec. 6015(e)(1)(A). 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 stand-alone section
6015(f) case where no deficiency has been asserted. The Tax
Relief and Health Care Act of 2006, Pub. L. 109-432, div. C, sec.
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