Alt v. Comm'r
United States Tax Court
P filed joint tax returns for taxable years 1982 to 1988 with H. H filed a return in 1989 with the filing status of "Married filing separate". P did not file a tax return in 1989. R determined deficiencies against P and H for taxable years 1982 to 1988. P sent R a Form 8857, Request for Innocent Spouse Relief, for taxable years 1982 to 1989. R sent P a notice of determination determining that P was not entitled to relief under I.R.C. sec. 6015(b), (c), and (f) for taxable…
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P filed joint tax returns for taxable years 1982 to 1988 with H. H filed a return in 1989 with the filing status of "Married filing separate". P did not file a tax return in 1989. R determined deficiencies against P and H for taxable years 1982 to 1988. P sent R a Form 8857, Request for Innocent Spouse Relief, for taxable years 1982 to 1989. R sent P a notice of determination determining that P was not entitled to relief under I.R.C. sec. 6015(b), (c), and (f) for taxable years 1982 to 1988. R sent P a letter determining that no relief under I.R.C. sec. 6015 was available for 1989 because P…
1Opinion of the Court
Vasquez, Judge:
This case arises from a request for relief under section 60151 with respect to petitioner’s taxable years 1982 to 1989 (years at issue). The issues for decision are: (1) Whether petitioner is entitled to relief under section 6015(b) for the years at issue; (2) whether petitioner is entitled to relief under section 6015(c) for the years at issue; and (3) whether respondent abused his discretion in denying petitioner relief under section 6015(f) for the years at issue.
FINDINGS OF FACT
On August 13, 2001, respondent filed a Motion to Show Cause Why Proposed Facts in Evidence Should…
2Cases cited7 opinions
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- United States v. RyersonSupreme Court of the United States · 1941
- Cheshire v. CommissionerUnited States Tax Court · 2000
- Jonson v. Comm'rUnited States Tax Court · 2002
- Ewing v. CommissionerUnited States Tax Court · 2002
2 more not listed; retrieve them via the Exa API.
3Cited by144 opinions
- Alt v. CommissionerCourt of Appeals for the Sixth Circuit · 2004
- Porter v. Comm'rUnited States Tax Court · 2009
- Ewing v. Comm'rUnited States Tax Court · 2004
- Hopkins v. Comm'rUnited States Tax Court · 2003
- Wilson v. CommissionerCourt of Appeals for the Ninth Circuit · 2013
139 more not listed; retrieve them via the Exa API.