Beery v. Comm'r
United States Tax Court
On Aug. 14, 2002, R issued to P a final notice disallowing her claims for relief from joint and several liability on a joint return for the taxable years 1989 to 1994. On Nov. 12, 2002, P filed with the Court a timely petition at docket No. 17597-02 challenging R's final notice disallowing her claims for relief from joint and several liability under sec. 6015, I.R.C.
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On Aug. 14, 2002, R issued to P a final notice disallowing her claims for relief from joint and several liability on a joint return for the taxable years 1989 to 1994. On Nov. 12, 2002, P filed with the Court a timely petition at docket No. 17597-02 challenging R's final notice disallowing her claims for relief from joint and several liability under sec. 6015, I.R.C. The "stand alone" I.R.C. sec. 6015 case, Joyce E. Beery, Petitioner, Jerome G. Beery, Intervenor, docket No. 17597-02, is currently pending before this Court. Meanwhile, on Nov. 6, 2002, R issued to P a Final Notice of Intent to…
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Chief Special Trial Judge Peter J., Panuthos, pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge:
This matter is before the Court on respondent’s motion for summary judgment, filed pursuant to Rule 121. As discussed in detail below, we shall grant respondent’s motion.
Background 2
In Beery v. Commissioner, T.C. Memo. 1996-464 (docket No. 26995-93), we…
2Cases cited10 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Zaentz v. CommissionerUnited States Tax Court · 1988
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3Cited by10 opinions
- Stein v. Comm'rUnited States Tax Court · 2004
- Nash v. Comm'rUnited States Tax Court · 2008
- Olender v. Comm'rUnited States Tax Court · 2008
- Stanwyck v. Comm'rUnited States Tax Court · 2012
- Laszloffy v. Comm'rUnited States Tax Court · 2007
5 more not listed; retrieve them via the Exa API.