Cathy Marie Lantz v. Commissioner

132 T.C. No. 8

UNITED STATES TAX COURT CATHY MARIE LANTZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25078-06. Filed April 7, 2009. P sought relief under sec. 6015(f), I.R.C., from joint income tax liability for 1999. R denied relief on the basis that P did not request relief within 2 years of R’s first collection action. Consequently, R did not reach the substantive issues of the claim. Both parties argue the validity of sec. 1.6015-5(b)(1), Income Tax Regs., which applies the 2-year limitations period to sec. 6015(f), I.R.C. Held: Sec. 1.6015-5(b)(1), Income Tax…