Legal Opinion

Ewing v. Comm'r

United States Tax Court

Decided January 28, 2004No. 1940-01Published

After submitting an application to and receiving an adverse determination from respondent (R), petitioner (P) petitioned this Court to seek our determination whether she is entitled to relief from joint liability under sec. 6015(f), I.R.C.

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After submitting an application to and receiving an adverse determination from respondent (R), petitioner (P) petitioned this Court to seek our determination whether she is entitled to relief from joint liability under sec. 6015(f), I.R.C. R contends that: (1) In making our determination, we may not consider evidence introduced at trial which was not included in the administrative record; and (2) whether or not our review is limited to R's administrative record, P is not entitled to equitable relief under sec. 6015(f), I.R.C. Held: Our determination whether P is entitled to relief under sec.…

1Opinion of the Court

GWENDOLYN A. EWING, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Ewing v. Comm'r

No. 1940-01

United States Tax Court

122 T.C. 32; 2004 U.S. Tax Ct. LEXIS 2; 122 T.C. No. 2;

January 28, 2004, Filed

Ewing v. Commissioner, 118 T.C. 494, 2002 U.S. Tax Ct. LEXIS 30 (2002)

Taxpayer entitled to equitable relief.

After submitting an application to and receiving an adverse

determination from respondent (R), petitioner (P) petitioned

this Court to seek our determination whether she is entitled to

relief from joint liability under sec. 6015(f), I.R.C. R contends that: (1) In making our determination,…

Also in this document: Concurrence · Wherry; Concurrence · Thornton; Dissent.

2Cases cited83 opinions

  1. Cooter & Gell v. Hartmarx Corp.Supreme Court of the United States · 1990
  2. United States v. RaddatzSupreme Court of the United States · 1980
  3. Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1978
  4. Camp v. PittsSupreme Court of the United States · 1973
  5. Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000

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