Kollar v. Comm'r
United States Tax Court
P filed a joint 1996 Federal income tax return reporting zero income tax liability. Before Dec. 20, 2006, P amended that return and paid the income tax reported on the amended return. P did not pay any statutory interest that had accrued as to that tax. R assessed accrued interest, and P requested from R equitable relief from the assessed interest pursuant to sec. 6015(f), I.R.C.
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P filed a joint 1996 Federal income tax return reporting zero income tax liability. Before Dec. 20, 2006, P amended that return and paid the income tax reported on the amended return. P did not pay any statutory interest that had accrued as to that tax. R assessed accrued interest, and P requested from R equitable relief from the assessed interest pursuant to sec. 6015(f), I.R.C. After R determined that P was not entitled to the requested relief, P petitioned the Court to review that determination under former sec. 6015(e)(1), I.R.C. Relying upon Billings v. Commissioner, 127 T.C. 7 (2006),…
1Opinion of the Court
OPINION
Marvel, Judge:
Respondent moves the Court to dismiss this case for lack of jurisdiction, asserting that the Court lacks jurisdiction under section 6015(e)(1) to review respondent’s determination that petitioner is not entitled to equitable relief under section 6015(f) (section 6015(f) relief).1 Petitioner requests section 6015(f) relief from her liability for accrued interest owed with respect to her 1996 Federal income tax paid in full before December 20, 2006. We decide whether section 6015(e)(1) gives the Court jurisdiction to decide this case. We hold it does.
Background
During 1996…
2Cases cited12 opinions
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Naftel v. CommissionerUnited States Tax Court · 1985
- Helvering v. BlissSupreme Court of the United States · 1934
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
7 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Boyle v. Comm'rUnited States Tax Court · 2016
- Torrisi v. Comm'rUnited States Tax Court · 2011
- Kollar v. Comm'rUnited States Tax Court · 2008
- Mary Ann Kollar v. CommissionerUnited States Tax Court · 2008