§60151

Held: Applying Rule 802 of the Federal Rules of Evidence, the Court overrules R’s hearsay objection.

We hold that she is to the extent stated herein.

We hold that she is to the extent stated herein.

MEMORANDUM FINDINGS OF FACT AND OPINION VASQUEZ, Judge: Respondent determined that petitioner did not qualify for relief from joint and several liability pursuant to section 60151 for 1995 and 1996.2 This case is before the 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.

MEMORANDUM FINDINGS OF FACT AND OPINION GALE, Judge: This case is before the Court on petitioner’s petition to review respondent’s denial of relief under section 60151 with respect to petitioner’s 1994 taxable year.

History of Innocent Spouse Requests Section 60151 offers (b), (c), and (f) relief, each named after its subsection.

MEMORANDUM FINDINGS OF FACT AND OPINION GALE, Judge: This proceeding was commenced under section 60151 for review of the Internal Revenue Service’s (IRS) determination that petitioner is not entitled to relief from joint and several liability with respect to joint federal income tax returns filed in her name for taxable years 2013–15 (years at issue).

-These consolidated cases arise from petitioner's requests for section 60151 reliefwith respect to the 1996-99 Federal income tax liabilities 1All section references aréto the Internal Revenue Còde in effect for the relevant years, and all Riile reference(cid:0)54à1i·e to the Tax Court Rules ofPractice and Procedure.

-These consolidated cases arise from petitioner's requests for section 60151 reliefwith respect to the 1996-99 Federal income tax liabilities 1All section references aréto the Internal Revenue Còde in effect for the relevant years, and all Riile reference(cid:0)54à1i·e to the Tax Court Rules ofPractice and Procedure.

KROUPA, Judge: This case arises from a petition for relief from joint and several liability under section 60151 after respondent issued a Final Notice of Determination Concerning Your Request for Relief From Joint and Several Liability under section 6015 denying petitioner relief from deficiencies for 1999 and 2000 (years at issue).

MEMORANDUM FINDINGS OF FACT AND OPINION KROUPA, Judge: This case arises from a stand-alone petition for relief from joint and several liability under section 60151 and relates to a deficiency notice issued by respondent to 1All section references are to the Internal Revenue Code of 1986, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.

MEMORANDUM FINDINGS OF FACT AND OPINION PARIS, Judge: Petitioner brings this case seeking review of respondent' s decision to deny petitioner relief from joint, and several liability under section 60151 with respect to income Section references are to the Internal Revenue Code of 1986, as amended.

MEMORANDUM FINDINGS OF FACT AND OPINION GUSTAFSON, Judge : This case arises from petitioner Callie Sue Olson's request for "innocent spouse" relief from joint liability under section 60151 for 2003 taxes--i .e ., an income tax 'Unless otherwise indicated, all citations of sections refer to the Internal Revenue Code of 1986 (26 U.S.C.), as amended, and all citations of Rules refer to the Tax Court Rules of Practic e (continued .

of section 60151 relief and review of respondent' s 1 Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Ta x (continued. . . ) SERVED Mar 31 2009 - , - rejection of other claims petitioner raised with respect to a notice of intent to levy and a notice of the filing of a lien . At t

MEMORANDUM FINDINGS OF FACT AND OPINION HAINES, Judge : This case arises under section 60151 from petitioner' s request for relief from ' joint and several liability 1Unless'otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure .

Section 60151(f) gives the. Commissioner discretion to;. grant relief-from joint and-several liability '>if, taking into account , all of the fact's and' 'circumstances 'it is inequitable to hold an individual liable for anykunpaid ''tax and relief :i s , not'available under section 6015(b) or (c), . As ° directed by 'section 6015 (f) , the Commiss

MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: This case arises under section 60151 from petitioner’s request for relief from joint and several liability for unpaid Federal income tax liabilities for 1979, 1980, and 1Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Section 60151(f) gives the. Commissioner discretion to;. grant relief-from joint and-several liability '>if, taking into account , all of the fact's and' 'circumstances 'it is inequitable to hold an individual liable for anykunpaid ''tax and relief :i s , not'available under section 6015(b) or (c), . As ° directed by 'section 6015 (f) , the Commiss

In February 2006, Suzanne filed a request for innocent- spouse relief under section 60151 with the Commissioner .

MEMORANDUM OPINION GERBER, Judge : In a petition filed April 27, 2006, petitioner alleged that respondent abused his discretion in denying her relief under section 60151 from joint income tax 1 All section references are to the Internal Revenue Code in effect for the period under consideration, and all Rule references are to the Tax Court's Rules of Practice and Procedure, unless otherwise indicated .

Section 6015(a) Unequivocally Provides That “Any determination [under section 6015] shall be made without regard to community property laws.” As the majority correctly points out, Congress in 1998 enacted section 60151 as a means of expanding relief to innocent spouses.

MEMORANDUM OPINION KROUPA, Judge: Respondent determined that petitioner is not entitled to relief from joint and several liability under section 60151 with respect to unpaid taxes reported on joint returns petitioner and her former spouse filed for 1998 and 1999 (the years at issue).

MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: This case arises from a request for relief under section 60151 with respect to petitioner’s 1992, 1993, 1994, and 1995 taxable years.

MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: This case arises from a request for relief under section 60151 with respect to petitioner’s 1980 through 1986 taxable years.

Except for section 60151 and unless otherwise indicated, subsequent section 1 Sec.

MEMORANDUM OPINION MARVEL, Judge: This case arises from a request for relief under section 60151 with respect to petitioner’s 1985 and 1986 taxable years.

MEMORANDUM OPINION COUVILLION, Special Trial Judge: Petitioner applied for relief from joint liability under section 60151 for the 1996 tax year based on Form 8857, Request for Innocent Spouse Relief.

MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL, Judge: This case arises from a request for relief under section 60151 with respect to petitioner’s 1998 taxable year.

VASQUEZ, Judge: This case arises from a request for relief under section 60151 with respect to petitioner’s taxable years 1982 to 1989 (years at issue).

Rowe (hereinafter petitioner) relief from joint and several liability pursuant to - 2 - section 60151 with respect to certain omitted income and erroneous deduction items giving rise to deficiencies.