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whether we have jurisdiction under section 6015(e)2 over
petitioner’s stand-alone case asserting a claim for equitable
relief under section 6015(f) for 1995, 1996, 1997, and 1998.
Background
Petitioner resided in Florida when the petition in this case
was filed.
Petitioner filed joint Federal income tax returns for the
years at issue with her former husband, Jonathan H. Green.
Petitioner paid the Federal income tax liabilities reported on
the 1995, 1996, 1997, and 1998 joint returns but did not pay the
tax liabilities reported on the 1999 and 2000 joint returns.
Respondent has not asserted a deficiency against petitioner for
any year at issue.
On February 3, 2003, respondent received petitioner’s Form
8857, Request for Innocent Spouse Relief, with a Statement
Regarding Request for Equitable Relief (statement) for 1995
through 2000 attached. In the statement, petitioner requested a
refund of tax paid for 1995 through 2000 under section 6015(f).
On March 24, 2006, respondent issued to petitioner a Notice
of Determination Concerning Relief from Joint and Several
Liability Under Section 6015 for 1999 and 2000, in which he
denied petitioner’s request for relief. Respondent, however, did
2Unless otherwise indicated, all section references are to
the Internal Revenue Code.
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