Rule 320. General

(a) Applicability: The Rules of this Title XXXI set forth the provisions which apply to actions for the determination of relief from joint and several liability on a joint return pursuant to Code Section 6015. Except as otherwise provided in this Title, the other Rules of Practice and Procedure of the Court, to the extent pertinent, are applicable to such actions.

(b) Jurisdiction: The Court shall have jurisdiction of an action for determination of relief from joint and several liability on a joint return under this Title when the conditions of Code Section 6015 have been satisfied.

(c) Form and Style of Papers: All papers filed in an action for determination of relief from joint and several liability on a joint return shall be prepared in the form and style set forth in Rule 23.

Effective Date

Title XXXI sets forth procedures for actions under section 6015(e) of this title, as added by section 3201 of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105–206, 112 Stat. 734 . Section 6015(e) of this title provides for the determination by the Tax Court of the appropriate relief available to a taxpayer under that section, and is effective with respect to any liability for tax arising after July 22, 1998, and any liability for tax arising on or before such date but remaining unpaid as of such date, except that the 2-year period for electing the benefits of that section shall not expire before the date which is 2 years after the date of the first collection activity after July 22, 1998. Similarly, the Rules of Title XXXI are effective with respect to actions for determination of relief from joint and several liability on a joint return commenced with respect to any liability for tax arising after July 22, 1998, and any liability for tax arising on or before such date but remaining unpaid as of such date.