Fernandez v. Commissioner
United States Tax Court
P submitted a request to R for innocent spouse relief pursuant to sec. 6015(b), (c), and (f), I.R.C. R mailed to P a determination which denied the requested relief. P filed a timely petition with the Court pursuant to sec. 6015(e), I.R.C. P seeks review of R's denial of relief under sec. 6015(b), (c), and (f), I.R.C. R moved to dismiss for lack of jurisdiction and to strike as to sec. 6015(f), I.R.C.
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P submitted a request to R for innocent spouse relief pursuant to sec. 6015(b), (c), and (f), I.R.C. R mailed to P a determination which denied the requested relief. P filed a timely petition with the Court pursuant to sec. 6015(e), I.R.C. P seeks review of R's denial of relief under sec. 6015(b), (c), and (f), I.R.C. R moved to dismiss for lack of jurisdiction and to strike as to sec. 6015(f), I.R.C. R further moved to strike certain allegations of fact raised by P in the petition. HELD: We have jurisdiction to review a request for innocent spouse relief under sec. 6015(f), I.R.C., when P…
1Opinion of the Court
OPINION
Cohen, Chief Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(5). Unless otherwise indicated, section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge:
This matter is before the Court on respondent’s motion to dismiss for lack of jurisdiction and to strike. The…
2Cases cited15 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Naftel v. CommissionerUnited States Tax Court · 1985
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- Pallottini v. CommissionerUnited States Tax Court · 1988
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