Christensen v. Commissioner

RAWLINSON, Circuit Judge:

Lanny L. Christensen appeals from the Tax Court’s summary judgment in favor of the Commissioner of Internal Revenue (Commissioner) on Christensen’s claim for equitable relief under 26 U.S.C. § 6015(f). The Tax Court determined that relief under § 6015(f) is available only to spouses who file a joint federal income tax return. Because the plain language, context, and legislative history of § 6015 support the Tax Court’s interpretation of the statute, we affirm.

I. BACKGROUND

On September 14, 2004, Christensen filed a request with the Internal Revenue Service (I.R.S.) for…