Harbin v. Comm'r
United States Tax Court
P filed a petition seeking relief from joint and several liability under sec. 6015, I.R.C. R contends that P is barred, under sec. 6015(g)(2), I.R.C., from seeking relief because P was involved and participated in the prior deficiency proceeding. P contends that he did not participate meaningfully in the prior deficiency proceeding. P's attorney in the prior deficiency proceeding also represented P's former spouse in that proceeding.
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P filed a petition seeking relief from joint and several liability under sec. 6015, I.R.C. R contends that P is barred, under sec. 6015(g)(2), I.R.C., from seeking relief because P was involved and participated in the prior deficiency proceeding. P contends that he did not participate meaningfully in the prior deficiency proceeding. P's attorney in the prior deficiency proceeding also represented P's former spouse in that proceeding. P's attorney had a conflict of interest while representing P in the prior deficiency proceeding. Held: P did not participate meaningfully in the prior deficiency…
1Opinion of the Court
Kroupa, Judge:
This case arises from a petition for relief from joint and several liability under section 60151 after respondent issued a Final Notice of Determination Concerning Your Request for Relief From Joint and Several Liability under section 6015 denying petitioner relief from deficiencies for 1999 and 2000 (years at issue). Petitioner argues that he is entitled to relief under section 6015 from liability for the portions of the deficiencies for the years at issue that are attributable to his former wife’s (intervenor) gambling activities (deficiencies at issue). We must decide whether…
2Cases cited7 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- National Life Insurance v. United StatesSupreme Court of the United States · 1928
- Gustafson v. CommissionerUnited States Tax Court · 1991
- VETRANO v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Thurner v. Comm'rUnited States Tax Court · 2003
2 more not listed; retrieve them via the Exa API.
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- Clark J. Gebman & Rebecca Gebman v. CommissionerUnited States Tax Court · 2017
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