Diane Fernandez, (2000)
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Diane Fernandez, (2000)
114 T.C. No. 21
UNITED STATES TAX COURT DIANE FERNANDEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16710-99. Filed May 10, 2000.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 makes a requisite election under sec. 6015(b) and/or (c), I.R.C., and files a timely petition with the Tax Court pursuant to sec. 6015(e), I.R.C. See Butler v. Commissioner, 114 T.C. ___ (2000). Accordingly, R's motion to dismiss for lack of juris...See the full content of this document
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