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HALL v. COMMISSIONER

Docket No. 30685-08.

135 T.C. 374 (2010)

AUDREY MARIE HALL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 22, 2010.

Attorney(s) appearing for the Case

Ljubomir Nacev, for petitioner.

Emily J. Giometti, for respondent.

OPINION

GOEKE, Judge:

This case is before the Court on petitioner's request for relief under section 6015(f).1 We have jurisdiction under section 6015(e).

The specific issue is whether petitioner is entitled to equitable relief under section 6015(f), notwithstanding her failure to request such relief before the 2-year deadline imposed by section 1.6015-5(b)(1), Income Tax Regs.

Background

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