Miller v. Commissioner
United States Tax Court
HELD: Sec. 6015, I.R.C., has no application to, and does not govern, (1) the request of P's former spouse for relief from joint and several liability under sec. 6013(e), I.R.C.
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HELD: Sec. 6015, I.R.C., has no application to, and does not govern, (1) the request of P's former spouse for relief from joint and several liability under sec. 6013(e), I.R.C. (former sec. 6013(e)), which was repealed effective July 22, 1998, and (2) the administrative proceedings conducted by R that ultimately resulted in R's granting that relief to her prior to July 22, 1998. HELD, FURTHER, P did not have the right to be notified of or to participate in the administrative proceedings relating to the request of P's former spouse for relief from joint and several liability under former sec.…
1Opinion of the Court
OPINION
CHIECHI, Judge:
This case is before the Court on respondent’s motion for judgment on the pleadings which was filed on June 12, 2000, and which, pursuant to Rule 120(b),1 the Court shall treat as respondent’s motion for summary judgment under Rule 121 (respondent’s motion). On July 10, 2000, petitioner filed a response to respondent’s motion, and on August 1, 2000, respondent filed a reply to petitioner’s response. On September 11, 2000, the Court held a hearing on respondent’s motion. As directed by the Court, respondent filed a supplement to respondent’s motion on October 2, 2000, in…
2Cases cited6 opinions
- Sego v. CommissionerUnited States Tax Court · 2000
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3Cited by30 opinions
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