A benevolent Congress having expanded the scope of Tax Court review of innocent spousery, ex-Ch J L Paige (“Iron Fist”) Marvel obliges us today with a checklist for the petitioner seeking Section 6015 relief. She expands and expatiates on the checklist of her predecessor, ex-Ch J Michael B (“Iron Mike”) Thornton; see my blogpost “First Checklist for Innocent Spouser,” 11/4/19.

Ilya Iussa, Docket No. 24775-18, filed 12/27/18, is a beneficiary of ex-Ch J Iron Fist’s precision.

First, let petitioner and IRS stip out whatever they can, especially the contents of the administrative record, which led to the denial or abridgment of the relief sought.

But if they cannot, the petitioner needs to make a list like this.

“(1) the reasons why she disagrees with the administrative record as submitted by respondent and, if applicable, what documents she believes should be included in or excluded from the administrative record; (2) whether she plans to introduce evidence outside the administrative record and, if so, on what basis; and (3) whether she believes that a trial is necessary and, if so, why.” Order, at p. 2.

Read and heed.