Gwendolyn A. Ewing v. Commissioner

122 T.C. No. 2

UNITED STATES TAX COURT GWENDOLYN A. EWING, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1940-01. Filed January 28, 2004. After submitting an application to and receiving an adverse determination from respondent (R), petitioner (P) petitioned this Court to seek our determination whether she is entitled to relief from joint liability under sec. 6015(f), I.R.C. R contends that: (1) In making our determination, we may not consider evidence introduced at trial which was not included in the administrative record; and (2) whether or not our review is limited…