Legal Opinion

Porter v. Comm'r

United States Tax Court

Decided May 15, 2008No. 13558-06Published

R denied P's application for relief from joint income tax liability under sec. 6015, I.R.C. P petitioned this Court to seek our determination whether she is entitled to relief under sec. 6015(f), I.R.C. R filed a motion in limine to preclude P from introducing at trial any evidence, documentary or testimonial, which was not available to R during the administrative process.

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R denied P's application for relief from joint income tax liability under sec. 6015, I.R.C. P petitioned this Court to seek our determination whether she is entitled to relief under sec. 6015(f), I.R.C. R filed a motion in limine to preclude P from introducing at trial any evidence, documentary or testimonial, which was not available to R during the administrative process. R urges us to reconsider our holding in Ewing v. Commissioner, 122 T.C. 32 (2004), vacated on unrelated jurisdictional grounds 439 F.3d 1009 (9th Cir. 2006). Held: We will continue to follow our holding in Ewing v.…

1Opinion of the Court

SUZANNE L. PORTER, A.K.A. SUZANNE L. HOLMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Porter v. Comm'r

No. 13558-06

United States Tax Court

130 T.C. 115; 2008 U.S. Tax Ct. LEXIS 10; 130 T.C. No. 10;

May 15, 2008, Filed

R denied P's application for relief from joint income tax liability under sec. 6015, I.R.C. P petitioned this Court to seek our determination whether she is entitled to relief under sec. 6015(f), I.R.C. R filed a motion in limine to preclude P from introducing at trial any evidence, documentary or testimonial, which was not available to R during the administrative…

Also in this document: Concurrence · Vasquez; Concurrence · Thornton; Concurrence · Goeke; Concurrence · Wherry.

2Cases cited65 opinions

  1. Camp v. PittsSupreme Court of the United States · 1973
  2. Bowen v. MassachusettsSupreme Court of the United States · 1988
  3. Reisman v. CaplinSupreme Court of the United States · 1964
  4. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  5. Lewis v. ReynoldsSupreme Court of the United States · 1932

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