Barnes v. Comm'r
United States Tax Court
On Nov. 24, 2000, P filed a request for equitable relief from joint and several liability with respect to her and her ex-spouse's 1997 tax underpayment. On Sept. 13, 2001, R issued a final notice of determination, denying the requested relief.
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On Nov. 24, 2000, P filed a request for equitable relief from joint and several liability with respect to her and her ex-spouse's 1997 tax underpayment. On Sept. 13, 2001, R issued a final notice of determination, denying the requested relief. On Mar. 7, 2007, P filed a second request for equitable relief with respect to the same underpayment, providing more detailed factual allegations and alleging that in 2002 her ex-husband and his business associate had been convicted of criminal securities fraud. By letter dated May 1, 2007, R declined to reconsider his original denial of relief. On July…
1Opinion of the Court
OPINION
Thornton, Judge:
This case arises from a request for relief from joint and several liability under section 6015(f) with respect to petitioner’s unpaid taxes for 1997.1 This case is before us on respondent’s motion to dismiss for lack of jurisdiction and petitioner’s motions to enjoin collection. For the reasons discussed below, we shall grant respondent’s motion to dismiss for lack of jurisdiction and deny petitioner’s motions to enjoin collection.
Background
On their joint 1997 Federal income tax return petitioner and her then spouse, Nathan Genrich (Mr. Genrich), reported but did not…
2Cases cited17 opinions
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- In the Matter of Herbert P. Carlson and Margaret P. Carlson, Debtors. Herbert P. Carlson and Margaret P. Carlson v. United StatesCourt of Appeals for the Seventh Circuit · 1997
- Charles G. Fargo Elizabeth A. Fargo v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Fargo v. Comm'rUnited States Tax Court · 2004
- Jeremiah Benzvi and Robert L. McLeroy v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
12 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Gray v. CommissionerUnited States Tax Court · 2012
- United States v. Judith BarnesCourt of Appeals for the Eleventh Circuit · 2012
- Barnes v. Comm'rUnited States Tax Court · 2008
- Judith A. Barnes, f.k.a. Judith Genrich v. CommissionerUnited States Tax Court · 2008
- Tu Pham v. Comm'rUnited States Tax Court · 2012
1 more not listed; retrieve them via the Exa API.