Legal Opinion
Wilson v. Commissioner
Court of Appeals for the Ninth Circuit
Decided January 15, 2013No. 10-72754PublishedCited by 33 opinions
1Opinion of the Court
Opinion by Judge THOMAS; Dissent by Judge BYBEE.
OPINION
THOMAS, Circuit Judge:
In this case, we consider how the Tax Court should review appeals for equitable innocent spouse relief from joint and several liability for unpaid taxes under 26 *982U.S.C. § 6015(f). We join the Eleventh Circuit and hold that the Tax Court properly considered new evidence outside the administrative record. We also conclude that the Tax Court correctly applied a de novo standard of review in determining the taxpayer’s eligibility for equitable relief. We affirm the judgment of the Tax Court.
I
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2Cases cited26 opinions
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Camp v. PittsSupreme Court of the United States · 1973
- Bowen v. MassachusettsSupreme Court of the United States · 1988
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Steadman v. Securities & Exchange CommissionSupreme Court of the United States · 1981
21 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Ana Flores v. Rod DanielsonCourt of Appeals for the Ninth Circuit · 2013
- Wallace v. Tesoro Corp.Court of Appeals for the Fifth Circuit · 2015
- Dixon v. United StatesCourt of Appeals for the Federal Circuit · 2023
- Federal Energy Regulatory Commission v. Barclays Bank PLCDistrict Court, E.D. California · 2017
- Earnest Woods, Ii v. Santos CervantesCourt of Appeals for the Ninth Circuit · 2013
28 more not listed; retrieve them via the Exa API.