Billings v. Comm'r
United States Tax Court
P's wife did not report embezzlement income on their joint 1999 return. After she was caught, P and she filed an amended tax return that reported the embezzlement income. P then applied for relief from joint and several liability under IRC sec. 6015(f). The Commissioner issued a notice of determination denying his request, and P filed a petition under sec. 6015(e) to review the Commissioner's determination.
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P's wife did not report embezzlement income on their joint 1999 return. After she was caught, P and she filed an amended tax return that reported the embezzlement income. P then applied for relief from joint and several liability under IRC sec. 6015(f). The Commissioner issued a notice of determination denying his request, and P filed a petition under sec. 6015(e) to review the Commissioner's determination. P and R stipulated that no relief is available under IRC sec. 6015(b) and (c). Held: Upon reconsideration, we no longer adhere to our prior holding that sec. 6015(e) gives us jurisdiction…
1Opinion of the Court
DAVID BRUCE BILLINGS Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Billings v. Comm'r
No. 6148-03
United States Tax Court
127 T.C. 7; 2006 U.S. Tax Ct. LEXIS 21; 127 T.C. No. 2;
July 25, 2006, Filed
P's wife did not report embezzlement income on their joint 1999
return. After she was caught, P and she filed an amended tax
return that reported the embezzlement income. P then applied for
relief from joint and several liability under IRC sec. 6015(f).
The Commissioner issued a notice of determination denying his
request, and P filed a petition under sec. 6015(e) to review the
Commissioner's…
Also in this document: Concurrence; Dissent · Chiechi; Dissent · Vasquez; Dissent · Marvel.
2Cases cited55 opinions
- United States v. BookerSupreme Court of the United States · 2004
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Lamie v. United States TrusteeSupreme Court of the United States · 2004
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
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