Petrane v. Comm'r
United States Tax Court
P filed a petition pursuant to sec. 6015(e), I.R.C., seeking relief from R's determination to deny spousal relief from unpaid joint tax liabilities for the years 1996-2000 and 2002. P requested that her case be conducted under the small tax case procedures authorized by sec. 7463(f)(1), I.R.C., "in the case of * * * a petition to the Tax Court under section 6015(e) in which the amount of relief sought does not exceed $ 50,000". On the date the petition was filed, the amount…
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P filed a petition pursuant to sec. 6015(e), I.R.C., seeking relief from R's determination to deny spousal relief from unpaid joint tax liabilities for the years 1996-2000 and 2002. P requested that her case be conducted under the small tax case procedures authorized by sec. 7463(f)(1), I.R.C., "in the case of * * * a petition to the Tax Court under section 6015(e) in which the amount of relief sought does not exceed $ 50,000". On the date the petition was filed, the amount of unpaid tax, interest, and penalties for which P sought relief did not exceed $ 50,000 for any single year, but the…
1Opinion of the Court
OPINION
Ruwe, Judge:
Petitioner timely filed a petition under section 6015(e)1 seeking review of respondent’s final determinations denying her relief from joint and several liability under section 6015 for the tax years 1996, 1997, 1998, 1999, 2000, and 2002. Petitioner requested that this case be conducted under section 7463, which provides for “small tax case” or “S case” procedures. Section 7463 generally allows disputes in small tax cases to be decided in proceedings in which the normally applicable procedural and evidentiary rules are relaxed. See Rule 174(b). This Opinion addresses…
2Cases cited12 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- Woodral v. CommissionerUnited States Tax Court · 1999
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Fernandez v. CommissionerUnited States Tax Court · 2000
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3Cited by9 opinions
- Leahy v. Comm'rUnited States Tax Court · 2007
- Kollar v. Comm'rUnited States Tax Court · 2008
- Devlin v. Comm'rUnited States Tax Court · 2007
- Gilda A. Petrane v. CommissionerUnited States Tax Court · 2007
- Kollar v. Comm'rUnited States Tax Court · 2008
4 more not listed; retrieve them via the Exa API.