Deihl v. Commissioner
United States Tax Court
In 2004 P and her husband litigated three consolidated cases before the Court concerning their 1996, 1997, and 1998 tax years. P's attorney raised the issue of relief from joint and several liability under sec. 6015, I.R.C., in the petition for 1996 but not 1997 or 1998. The request did not invoke any specific subsection of sec. 6015, I.R.C. P then withdrew her claim for relief from joint and several liability in the stipulation of facts for the consolidated cases.
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In 2004 P and her husband litigated three consolidated cases before the Court concerning their 1996, 1997, and 1998 tax years. P's attorney raised the issue of relief from joint and several liability under sec. 6015, I.R.C., in the petition for 1996 but not 1997 or 1998. The request did not invoke any specific subsection of sec. 6015, I.R.C. P then withdrew her claim for relief from joint and several liability in the stipulation of facts for the consolidated cases. P's husband died after the opinion in the consolidated cases was filed but before decisions were entered. After decisions were…
1Opinion of the Court
OPINION
Vasquez, Judge:
Petitioner seeks review of respondent’s determination that she is not entitled to relief from joint and several liability under section 6015(b), (c), and (f) 1 with respect to her joint Federal income tax liabilities for 1996, 1997, and 1998. Our jurisdiction to review petitioner’s request for relief is conferred by section 6015(e). The only issue for decision is whether petitioner is precluded by the doctrine of res judicata as set forth in section 6015(g)(2) from raising the issue of relief from joint and several liability for the years in issue. 2
Background
Petitioner…
2Cases cited12 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Jonson v. Comm'rUnited States Tax Court · 2002
- Jonson v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
- Gustafson v. CommissionerUnited States Tax Court · 1991
- In Re Clayton Baker Sally I. Baker, Debtors. Clayton Baker Sally I. Baker v. Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1996
7 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Haag v. ShulmanCourt of Appeals for the First Circuit · 2012
- Harbin v. Comm'rUnited States Tax Court · 2011
- John E. Rogers & Frances L. Rogers v. CommissionerUnited States Tax Court · 2018
- Harbin v. Comm'rUnited States Tax Court · 2011
- Leonard W. Harbin, and Bernice Nalls, Intervenor v. CommissionerUnited States Tax Court · 2011
1 more not listed; retrieve them via the Exa API.