Friday v. Comm'r
United States Tax Court
P filed a petition seeking relief from joint and several tax liability under sec. 6015, I.R.C., and R moved for summary judgment. R then moved to withdraw his summary judgment motion. The Court granted the motion to withdraw. R also moved the Court to "remand" this matter to R's office that specializes in sec. 6015, I.R.C., cases for further consideration by R before any further consideration by the Court. Held: R's motion for remand will be denied.
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P filed a petition seeking relief from joint and several tax liability under sec. 6015, I.R.C., and R moved for summary judgment. R then moved to withdraw his summary judgment motion. The Court granted the motion to withdraw. R also moved the Court to "remand" this matter to R's office that specializes in sec. 6015, I.R.C., cases for further consideration by R before any further consideration by the Court. Held: R's motion for remand will be denied. Held further: This case will be returned to the general docket for trial in due course.
1Opinion of the Court
OPINION
Gerber, Chief Judge:1
Respondent issued a notice of determination to petitioner denying her request for relief under section 60152 and specifically finding that she was ineligible for relief under section 6015(b), (c), or (f). Petitioner filed a petition with this Court seeking relief from joint and several liability. On October 12, 2004, respondent filed a motion for summary judgment.
At the hearing, relying on our holding in McGee v. Commissioner, 123 T.C. 314 (2004), respondent moved to withdraw his summary judgment motion, and the Court granted respondent’s motion to withdraw.…
2Cases cited8 opinions
- Camp v. PittsSupreme Court of the United States · 1973
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
- Asarco, Inc. v. U. S. Environmental Protection AgencyCourt of Appeals for the Ninth Circuit · 1980
- Cheshire v. CommissionerUnited States Tax Court · 2000
- Kathryn Cheshire v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2002
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3Cited by25 opinions
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