Marianne Hopkins - Page 7

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               Petitioner and Mr. Hopkins reported, but did not pay, taxes            
          due of $1,571 and $3,326 on their joint income tax returns for              
          1988 and 1989, respectively.  Respondent assessed those amounts.            
               On May 24, 1999, petitioner filed with respondent a Form               
          8857, Request for Innocent Spouse Relief, with respect to her               
          1982, 1983, 1984, 1988, and 1989 joint tax liabilities.  On                 
          January 8, 2001, petitioner filed a petition for relief from                
          joint and several liability with this Court.  At the time the               
          petition was filed, respondent had not made a determination with            
          respect to petitioner’s request.8                                           
                                       OPINION                                        
          A.  Tax Liabilities for 1982, 1983, and 1984                                
               Petitioner claims that she is entitled to relief from joint            
          and several liability under section 6015(b), (c), or (f) for the            
          tax liabilities attributable to the disallowance of the Far West            
          Drilling partnership deductions and the disallowance of the NOL             
          carryforward deductions for 1982, 1983, and 1984.                           









               8Pursuant to sec. 6015(e)(1)(A), a petition may be filed               
          with this Court after the passage of 6 months from the date the             
          taxpayer elected sec. 6015 relief if the Commissioner has made no           
          determination regarding the election.                                       




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