Gilda A. Petrane v. Commissioner

129 T.C. No. 1

UNITED STATES TAX COURT GILDA A. PETRANE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2011-07. Filed July 24, 2007. P filed a petition pursuant to sec. 6015(e), I.R.C., seeking relief from R’s determination to deny spousal relief from unpaid joint tax liabilities for the years 1996-2000 and 2002. P requested that her case be conducted under the small tax case procedures authorized by sec. 7463(f)(1), I.R.C., “in the case of * * * a petition to the Tax Court under section 6015(e) in which the amount of relief sought does not exceed $50,000”. On the date…