Washington v. Comm'r
United States Tax Court
P and her then h usband, H, filed a joint Federal income tax return for 1989 showing tax owed; they did not pay the tax with the return. R garnished P's wages and applied P's overpayments of tax from 1992 and 1994-98 to the unpaid 1989 tax liability. P requested relief under sec. 6015(f), I.R.C. R denied P's request for relief.
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P and her then h usband, H, filed a joint Federal income tax return for 1989 showing tax owed; they did not pay the tax with the return. R garnished P's wages and applied P's overpayments of tax from 1992 and 1994-98 to the unpaid 1989 tax liability. P requested relief under sec. 6015(f), I.R.C. R denied P's request for relief. P then filed a petition in this Court seeking a review of R's determination and requesting (pursuant to sec. 6015(g), I.R.C.) a refund of her garnished wages and the o verpayments of tax from 1992 and 1994-98. R a sserts that even if P is entitled to relief under sec.…
1Opinion of the Court
Jacobs, Judge:
Respondent determined that petitioner is not entitled to relief from joint liability for tax under section 6015(f) for 1989 with respect to a joint return filed with Kenneth Washington.1 Petitioner filed a petition under section 6015(e)(1) seeking review of respondent’ determination.
The issues for decision are (1) whether respondent’s denial of petitioner’s request for relief pursuant to section 6015(f) was an abuse of discretion, and, if so, (2) whether petitioner is entitled to a refund of all amounts paid/applied toward the tax shown as owed on the 1989 joint return.
FINDINGS…
2Cases cited21 opinions
- Duncan v. WalkerSupreme Court of the United States · 2001
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- Flora v. United StatesSupreme Court of the United States · 1960
- BUTLER v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
- United States v. RyersonSupreme Court of the United States · 1941
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