Ordlock v. Comm'r
United States Tax Court
P resides in a community property State. P and H filed joint tax returns for 1982, 1983, and 1984. P and H paid the reported tax liabilities. Additional tax liabilities -- i.e., understatements -- arose that were attributable to erroneous items of H (H's understatements). The parties agree that P is entitled to sec. 6015(b), I.R.C., relief for the years in issue and P's liability for these years is zero after application of sec. 6015(b), I.R.C.
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P resides in a community property State. P and H filed joint tax returns for 1982, 1983, and 1984. P and H paid the reported tax liabilities. Additional tax liabilities -- i.e., understatements -- arose that were attributable to erroneous items of H (H's understatements). The parties agree that P is entitled to sec. 6015(b), I.R.C., relief for the years in issue and P's liability for these years is zero after application of sec. 6015(b), I.R.C. After the years at issue until the present, R applied numerous payments to H's understatements. One payment was from P's "separate property", as…
1Opinion of the Court
OPINION
Goeke, Judge:
Respondent determined that petitioner is entitled to relief under section 6015(b).1 The issue for decision is the amount of refund, if any, petitioner is entitled to under section 6015(g).
Background
The parties submitted this case fully stipulated under Rule 122. The stipulation of facts and the attached exhibits are incorporated herein by this reference.
On July 26, 2002, respondent sent petitioner a Notice of Determination Concerning Your Request for Relief from Joint and Several Liability Under Section 6015 (notice of determination). The notice of determination indicates…
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- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Aquilino v. United StatesSupreme Court of the United States · 1960
- McCarty v. McCartySupreme Court of the United States · 1981
- Morgan v. CommissionerSupreme Court of the United States · 1940
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3Cited by15 opinions
- Ordlock v. CommissionerCourt of Appeals for the Ninth Circuit · 2008
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