Adkison v. Commissioner

BYBEE, Circuit Judge:

Peter Adkison appeals the Tax Court’s dismissal of his claim for relief under 26 U.S.C. § 6015 for lack of jurisdiction. Section 6015(c) 1 allows a former spouse who once filed a joint return and now, no longer married, meets certain requirements to claim relief from joint and several liability for a tax deficiency. The Tax Court held that it lacked jurisdiction because Adkison’s deficiency stemmed from a partnership interest that is the subject of an ongoing partnership proceeding under the Tax Equity and Fiscal Responsibility Act (TEFRA) and regulated by a separate set…