Legal Opinion

Billings v. Comm'r

United States Tax Court

Decided July 25, 2006No. 6148-03Published

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

  1. United States v. BookerSupreme Court of the United States · 2004
  2. Connecticut National Bank v. GermainSupreme Court of the United States · 1992
  3. Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
  4. Lamie v. United States TrusteeSupreme Court of the United States · 2004
  5. Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982

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