- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008