Koprowski v. Commissioner
United States Tax Court
P and W filed a joint return for 2006. R issued a notice of deficiency, and P and W filed a petition asking this Court to redetermine that deficiency. They elected to have the case proceed under small tax case procedures pursuant to I.R.C. sec. 7463. P signed the petition and all other filings.
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P and W filed a joint return for 2006. R issued a notice of deficiency, and P and W filed a petition asking this Court to redetermine that deficiency. They elected to have the case proceed under small tax case procedures pursuant to I.R.C. sec. 7463. P signed the petition and all other filings. P and W moved for summary judgment; R cross-moved for summary judgment; and P and W opposed on various grounds, including P's entitlement to innocent spouse relief from joint liability under I.R.C. sec. 6015. At a calendar call before the Court, P spoke for himself and W. The parties withdrew their…
1Opinion of the Court
OPINION
Gustafson, Judge-.
Petitioner Eugene Koprowski seeks this Court’s review, pursuant to section 6015(e),1 of the denial by the Internal Revenue Service (IRS) of his request for relief from his liability for income tax for 2006, for which he filed a joint return with his wife. The case is currently before the Court on a motion for summary judgment filed by respondent (the IRS) under Rule 121. We will grant that motion and sustain the IRS’s determination on grounds of res judicata.
Background
The following facts are based on the petition, our record in Mr. Koprowski’s prior deficiency case…
2Cases cited19 opinions
- Allen v. McCurrySupreme Court of the United States · 1980
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
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