- 8 - II. Equitable Jurisdiction Petitioner argues that the Court should retain jurisdiction to determine whether petitioner was a signatory to the joint returns for 1995, 1996, 1997, and 1998. Petitioner asserts that because she signed the joint returns under duress and coercion, she did not have the requisite intent to file a joint return. In effect, petitioner is asking this Court to exercise jurisdiction over petitioner’s claims under general equitable principles. Petitioner has cited no statute or case that supports her argument that we can or should exercise jurisdiction independent of any conferred by section 6015(e). The only cases that she cites in support of her argument that we have equitable jurisdiction to decide whether she signed her 1995-98 joint returns under duress are deficiency cases in which the Commissioner issued notices of deficiency and the taxpayers timely petitioned this Court. See Stanley v. Commissioner, 81 T.C. 634 (1983); Brown v. Commissioner, 51 T.C. 116 (1968). Petitioner never received a notice of deficiency for 1995- 98. Consequently, we do not have jurisdiction to redetermine a deficiency under section 6213(a). In addition, for reasons described earlier in this opinion, we do not have jurisdiction over petitioner’s section 6015(f) claims for 1995-98 under section 6015(e) as amended. Petitioner has not asserted any basis for us to exercise jurisdiction over her claims.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: March 27, 2008