Tipton v. Comm'r
United States Tax Court
P petitioned this Court for redetermination of a deficiency. Subsequently, during a conference with R's Appeals Office, P requested relief from joint and several liability pursuant to sec. 6015, I.R.C. Pursuant to Rule 325(a), Tax Court Rules of Practice and Procedure, R notified I of P's request for sec. 6015, I.R.C., relief and of I's right to intervene. I filed a notice of intervention.
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P petitioned this Court for redetermination of a deficiency. Subsequently, during a conference with R's Appeals Office, P requested relief from joint and several liability pursuant to sec. 6015, I.R.C. Pursuant to Rule 325(a), Tax Court Rules of Practice and Procedure, R notified I of P's request for sec. 6015, I.R.C., relief and of I's right to intervene. I filed a notice of intervention. I was sent a notice of trial by the Court and was also notified by R that R would afford P complete sec. 6015, I.R.C., relief if I failed to appear at trial. I failed to appear at trial, and R filed a…
1Opinion of the Court
OPINION
Wells, Judge:
The instant case is before the Court on respondent’s motion to dismiss Darren L. Darilek (interve-nor) for failure properly to prosecute. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
Petitioner and intervenor filed a joint tax return for taxable year 2002 and divorced in 2003. On March 8, 2005, respondent issued a notice of deficiency determining a deficiency of $7,173 in petitioner and intervenor’s Federal income tax for taxable year…
2Cases cited6 opinions
- Link v. Wabash RailroadSupreme Court of the United States · 1962
- Vinson v. Washington Gas Light Co.Supreme Court of the United States · 1944
- Corson v. CommissionerUnited States Tax Court · 2000
- King v. CommissionerUnited States Tax Court · 2000
- Van Arsdalen v. Comm'rUnited States Tax Court · 2004
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3Cited by14 opinions
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- Jones v. United StatesDistrict Court, S.D. Illinois · 2021
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