Arlene L. Pollock v. Commissioner

132 T.C. No. 3

UNITED STATES TAX COURT ARLENE L. POLLOCK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17755-07. Filed February 12, 2009. P sought relief from joint liability for unpaid taxes under sec. 6015, I.R.C. R sent her a notice of determination denying relief, but at a time before Congress gave the Tax Court jurisdiction to review such denials. R then sought to collect the taxes in a lien- enforcement action. This prompted the District Court hearing the lien-enforcement action to invoke the doctrine of equitable tolling and give P 30 days to file a petition…