Magdalene H. Smolen, (2010)

Extract

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Magdalene H. Smolen, (2010)

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.

T.C. Summary Opinion 2010-106

UNITED STATES TAX COURT MAGDALENE H. SMOLEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13018-08S. Filed July 29, 2010.

Matthew F. Sarnell, for petitioner. Michelle Maniscalco, for respondent.

WELLS, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed. Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case. This case arises from a request for relief pursuant to section 6015(f) with respect to petitioner's joint income tax liability for 2005. Respondent determined that petitioner was not entitled to relief from joint and several liability under section 6015(f). Petitioner timely filed a petition with the Court. The issue...

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