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ADKISON v. C.I.R.

No. 08-70485.

592 F.3d 1050 (2010)

Peter D. ADKISON, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed January 21, 2010.

Attorney(s) appearing for the Case

Cori Flanders-Palmer (argued), Chicoine & Hallert, P.S., Seattle, Washington; John M. Colvin, Chicoine & Hallert, P.S., Seattle, Washington, for the petitioner-appellant.

Teresa E. McLaughlin (argued), United States Department of Justice, Tax Division, Washington, D.C.; Randolph L. Hutter, United States Department of Justice, Tax Division, Washington, D.C. for the respondent-appellee.

Before HAWKINS, M. MARGARET McKEOWN, and JAY S. BYBEE, Circuit Judges.

BYBEE, Circuit Judge:

Peter Adkison appeals the Tax Court's dismissal of his claim for relief under 26 U.S.C. § 6015 for lack of jurisdiction. Section 6015(c)1 allows a former spouse who once filed a joint return and now, no longer married, meets certain requirements to claim relief from joint and several liability for a tax deficiency. The Tax Court held that it lacked jurisdiction because Adkison's deficiency stemmed from a partnership...

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