In a taxpayer's appeal from a tax court's dismissal of his claim for relief from joint and several tax liability with his spouse under 26 U.S.C. section 6015, the order is affirmed where the deficiency challenged by the taxpayer stemmed from a partnership interest that was the subject of an ongoing partnership proceeding under the Tax Equity and Fiscal Responsibility Act and regulated by a separate set of provisions.
Argued and Submitted September 2, 2009
Filed January 21, 2010
Opinion by Judge Bybee
Cori Flanders-Palmer, Chicoine & Hallert, P.S., Seattle, WA
Teresa E. McLaughlin and Randolf L. Hutter, United States Department of Justice, Tax Division, Washington, DC