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McGEE v. COMMISSIONER

Docket No. 2884-03.

123 T.C. 314 (2004)

123 T.C. No. 19

NATALIE W. McGEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 18, 2004.

Attorney(s) appearing for the Case

Natalie W. McGee, pro se.

Marshall R. Jones, for respondent.

OPINION

GOEKE, Judge:

The sole matter before the Court is whether it was an abuse of discretion for respondent to deny petitioner's request for equitable relief from joint liability based on section 6015(f)1 solely because petitioner made her request more than 2 years after respondent's first collection activity.

Petitioner challenges the application of the 2-year limit on section 6015(f) requests imposed by Rev...

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