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In the Tipton v. Commr. case, the petitioner petitioned the Tax Court for redetermination of a deficiency. Subsequently, during a conference with the IRS' Appeals Office, the petitioner requested relief from joint and several liability pursuant to Section 6015. Pursuant to Rule 325(a), Tax Court Rules of Practice and Procedure, the IRS notified the intervenor of the petitioner's request for Section 6015 relief and of the intervenor's right to intervene. The intervenor filed a notice of intervention and was sent a notice of trial by the court and was also notified by the IRS that the IRS would afford the petitioner complete Section 6015 relief if the intervenor failed to appear at trial. The Tax Court held that the intervenor, who was sent notice of trial but failed to appear at the tria...
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In the Kovitch v. Commr. case, the IRS determined a deficiency with respect to the joint return that petitioner and intervenor filed for 2002. The petitioner filed a petition in which the only issue raised was her entitlement to spousal relief pursuant to Section 6015. The intervenor did not file a petition. The IRS notified the intervenor of the petitioner's petition and his right to intervene pursuant to Section 6015(e)(4) and Rule 325 of the Tax Court Rules of Practice and Procedure. The intervenor filed a notice of intervention and shortly thereafter filed for bankruptcy. Pursuant to 11 U.S.C. Section 362(a)(8) (2000), a bankruptcy filing gives rise to an automatic stay of proceedings in the Tax Court "concerning the debtor." The automatic stay with respect to the intervenor's bankr...
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T.C. Memo. 2010-34
UNITED STATES TAX COURT DANIKA K. KOSOLA, Petitioner AND JASON A. KOSOLA, Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Responde...
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T.C. Memo. 2009-249
UNITED STATES TAX COURT LINDA A. BRUEN, Petitioner, AND MICHAEL F. BRUEN, Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Respond...
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T.C. Memo. 2011-202
UNITED STATES TAX COURT MICHELLE POUNDS, Petitioner, AND DARRYL JOHNSON, Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Responde...
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- Grace United Methodist Church, Plaintiff-Appellant, v. City of Cheyenne; City of Cheyenne Board of Adjustment; Dorothy Wilson, City of Cheyenne Development Director; Cheyenne City Council, Defendant-Appellees, Mountview Park Homeowners' Association, Defendant-Intervenor-Appellee, United States of America, Plaintiff-Intervenor-Intervenor, the Becket Fund for Religious Liberty, Amicus Curiae., 451 F.3d 643 (10th Cir. 2006)
Stephen H. Kline, of Kline Law Office, Cheyenne, Wyoming (Michael D. Basom, Attorney for City of Cheyenne, Cheyenne, Wyoming, on the brief), for the D...
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T.C. Memo. 2012-11
UNITED STATES TAX COURT FARZANA ZAHER, Petitioner, AND MOHAMMAD ZAHER, Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Respondent ...
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T.C. Memo. 2011-280
UNITED STATES TAX COURT KAMAL A. HIRAMANEK, Petitioner, AND ADIL HIRAMANEK, Intervenor v. COMMISSIONER OF INTERNAL REVENUE, Respo...