Legal Opinion

Lincir v. Comm'r

United States Tax Court

Decided April 11, 2007No. 10138-04UnpublishedCited by 1 opinion

P and her former spouse were parties to earlier litigation in this Court in which P stipulated she was not entitled to relief under former sec. 6013(e), I.R.C. 1986. After this stipulation was filed and before this Court issued its first opinion in the earlier litigation, the Congress enacted sec. 6015(b) and (c), I.R.C. 1986, which provides avenues of relief that were not available under the former statute.

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P and her former spouse were parties to earlier litigation in this Court in which P stipulated she was not entitled to relief under former sec. 6013(e), I.R.C. 1986. After this stipulation was filed and before this Court issued its first opinion in the earlier litigation, the Congress enacted sec. 6015(b) and (c), I.R.C. 1986, which provides avenues of relief that were not available under the former statute. The Congress also enacted sec. 6015(g)(2), I.R.C. 1986, which provides that a final court decision "shall be conclusive" except as to qualification for relief under sec. 6015(b) or (c),…

1Opinion of the Court

DIANE C. LINCIR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Lincir v. Comm'r

No. 10138-04

United States Tax Court

T.C. Memo 2007-86; 2007 Tax Ct. Memo LEXIS 84; 93 T.C.M. (CCH) 1098;

April 11, 2007, Filed

Lincir v. Comm'r, 32 Fed. Appx. 278, 2002 U.S. App. LEXIS 3010 (9th Cir., 2002)

P and her former spouse were parties to earlier litigation in

this Court in which P stipulated she was not entitled to relief

under former sec. 6013(e), I.R.C. 1986. After this stipulation was filed and before this Court issued its first opinion in the

earlier litigation, the Congress enacted sec. 6015(b)…

2Cases cited25 opinions

  1. Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Cromwell v. County of SacSupreme Court of the United States · 1877
  4. Associated Press v. United StatesSupreme Court of the United States · 1945
  5. Associated Press v. United StatesSupreme Court of the United States · 1945

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3Cited by1 opinion

  1. Deihl v. CommissionerUnited States Tax Court · 2010

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