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LANTZ v. COMMISSIONER OF INTERNAL REVENUE

No. 25078-06.

132 T.C. No. 8

CATHY MARIE LANTZ, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States tax Court.

Filed April 7, 2009.

Attorney(s) appearing for the Case

Paul M. Kohlhoff and Robert B. Nadler, for petitioner.

Timothy S. Sinnott, for respondent.

OPINION

GOEKE, Judge.

Petitioner brought this case under section 60151 seeking review of respondent's denial of relief from joint income tax liability for 1999. Respondent denied relief solely because petitioner did not request relief from joint tax liability within 2 years of the time respondent took a collection action against petitioner for the joint tax liability. Both parties have argued the validity of section 1.6015-5...

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