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February 28, 2002.3 Petitioner’s 1992 nonmaster file transcript
also shows that respondent essentially had granted some form of
section 6015 relief to petitioner. Respondent allocated $3,211
of the tax (approximately 45.5 percent) and $374.47 of the
addition to tax (45.5 percent) for 1992 to petitioner. Starting
with June 1993, respondent assessed interest on these amounts
quarterly. On April 15, 1999, respondent applied $1,921.62 of
petitioner’s 1998 overpayment to reduce the balance of the tax
allocated to petitioner.4 On April 15, 2000, respondent applied
$1,998.12 of petitioner’s 1999 overpayment to reduce the balance
of the tax allocated to petitioner. Respondent also applied
$515.29 of petitioner’s 1999 overpayment to reduce the balance of
the addition to tax allocated to petitioner.
On February 14, 2002, respondent mailed petitioner a notice
of determination concerning your request for relief from joint
and several liability under section 6015 (notice of
determination). Respondent determined that petitioner was
eligible for relief pursuant to section 6015(f) of $3,5855 for
3 It is unclear why the transcript shows the amount
petitioner’s balance will be as of Feb. 28, 2002, rather than as
of the date the transcript was printed.
4 Respondent applied the remainder of petitioner’s 1998
overpayment ($949.38) to petitioner’s outstanding employment tax
liabilities.
5 The similarity of numerical figures present in this case
appears to be no more than coincidence.
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Last modified: May 25, 2011