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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.
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Last modified: March 27, 2008