Ewing v. Comm'r
United States Tax Court
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.
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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 to R's administrative record, P is not entitled to equitable relief under sec. 6015(f), I.R.C. Held: Our determination whether P is entitled to relief under sec.…
1Opinion of the Court
COLVIN, Judge:
Respondent determined that petitioner is not entitled to relief from joint liability for tax under section 6015(f) for 1995. Petitioner filed a petition under section 6015(e)(1) seeking our determination whether she is entitled to relief under section 6015(f).
The issues for decision are:1(1) Whether, in determining petitioner’s eligibility for relief under section 6015(f), we may consider evidence introduced at trial which was not included in the administrative record. We hold that we may;(2) whether petitioner is entitled to relief from joint liability for tax under section…
2Cases cited49 opinions
- Camp v. PittsSupreme Court of the United States · 1973
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- Florida Power & Light Co. v. LorionSupreme Court of the United States · 1985
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
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3Cited by93 opinions
- James M. Robinette v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Eighth Circuit · 2006
- Robinette v. Comm'rUnited States Tax Court · 2004
- Commissioner of Internal Revenue v. Gwendolyn A. Ewing, Gwendolyn A. Ewing v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Porter v. Comm'rUnited States Tax Court · 2008
- Billings v. Comm'rUnited States Tax Court · 2006
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