Harbin v. Comm'r
United States Tax Court
P filed a petition seeking relief from joint and several liability under sec. 6015, I.R.C. R contends that P is barred, under sec. 6015(g)(2), I.R.C., from seeking relief because P was involved and participated in the prior deficiency proceeding. P contends that he did not participate meaningfully in the prior deficiency proceeding. P's attorney in the prior deficiency proceeding also represented P's former spouse in that proceeding.
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P filed a petition seeking relief from joint and several liability under sec. 6015, I.R.C. R contends that P is barred, under sec. 6015(g)(2), I.R.C., from seeking relief because P was involved and participated in the prior deficiency proceeding. P contends that he did not participate meaningfully in the prior deficiency proceeding. P's attorney in the prior deficiency proceeding also represented P's former spouse in that proceeding. P's attorney had a conflict of interest while representing P in the prior deficiency proceeding. Held: P did not participate meaningfully in the prior deficiency…
1Opinion of the Court
LEONARD W. HARBIN, Petitioner, AND BERNICE NALLS, Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Harbin v. Comm'r
Docket No. 9994-07.
United States Tax Court
137 T.C. 93; 2011 U.S. Tax Ct. LEXIS 39; 137 T.C. No. 7;
September 26, 2011, Filed
Decision will be entered for petitioner.
P filed a petition seeking relief from joint and several liability under sec. 6015, I.R.C. R contends that P is barred, under sec. 6015(g)(2), I.R.C., from seeking relief because P was involved and participated in the prior deficiency proceeding. P contends that he did not participate meaningfully in the prior…
2Cases cited8 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- National Life Insurance v. United StatesSupreme Court of the United States · 1928
- Gustafson v. CommissionerUnited States Tax Court · 1991
- VETRANO v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Thurner v. Comm'rUnited States Tax Court · 2003
3 more not listed; retrieve them via the Exa API.