(United States Third Circuit) - In a petition challenging the IRS's final determinations denying her requests for relief for tax liability under the harmless spouse relief provisions of 26 U.
S.
C. section 6015, the United States Tax Court's dismissal of her petition for lack of jurisdiction is affirmed where: 1) petitioner failed to file her petition by the deadline set forth in 26 U.
S.
C. section 6015(e)(1)(A); and 2) the deadline is jurisdictional.
Source: findlaw.com