Block v. Comm'r
United States Tax Court
P requested relief from joint and several income tax liability pursuant to sec. 6015, I.R.C., regarding taxes that had been previously assessed for the taxable years 1983 and 1984. R issued a notice of determination denying P's request, and pursuant to sec. 6015(e), I.R.C., P filed a timely petition seeking review of R's determination.
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P requested relief from joint and several income tax liability pursuant to sec. 6015, I.R.C., regarding taxes that had been previously assessed for the taxable years 1983 and 1984. R issued a notice of determination denying P's request, and pursuant to sec. 6015(e), I.R.C., P filed a timely petition seeking review of R's determination. Thereafter, P moved to amend her petition pursuant to Rule 41(a), Tax Court Rules of Practice and Procedure, in order to claim that "The statute of limitation bars the assessment of the underlying income tax liabilities for 1983 and 1984." R opposed the…
1Opinion of the Court
OPINION
Ruwe, Judge:
This matter is before the Court on petitioner’s motion for leave to amend petition pursuant to Rule 41(a).1 Petitioner timely filed her petition with this Court pursuant to section 6015(e) seeking relief from her previously assessed joint and several income tax liabilities for 1983 and 1984.2 The petition was filed after respondent issued a notice of determination denying her request for relief.3
Section 6015(e) “allows a spouse who has requested relief to petition the Commissioner’s denial of relief, or to petition the Commissioner’s failure to make a timely determination.…
2Cases cited16 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- Naftel v. CommissionerUnited States Tax Court · 1985
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- Woods v. CommissionerUnited States Tax Court · 1989
11 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Hopkins v. Comm'rUnited States Tax Court · 2003
- Billings v. Comm'rUnited States Tax Court · 2006
- Rosenthal v. Comm'rUnited States Tax Court · 2004
- Levy v. Comm'rUnited States Tax Court · 2005
- Estate of Harriet Sommer v. Comm'rUnited States Tax Court · 2010
25 more not listed; retrieve them via the Exa API.