Sybil M. Smith - Page 3




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          February 5, 1996, a deficiency in the amount of $2,745 was                  
          assessed based on a defaulted notice of deficiency.  No payments            
          were made on the 1992 account prior to July 22, 1998.                       
               Petitioner originally sought administrative relief from the            
          Internal Revenue Service under prior section 6013(e).  For 1987,            
          respondent determined that petitioner was entitled to relief from           
          liability with respect to a deficiency determined for that year,            
          but not with respect to the tax reported on the return but not              
          paid and penalties relating thereto.  When section 6015 was                 
          adopted in 1998 (repealing section 6013(e)), petitioner’s claim             
          was reconsidered under the new Code section.  Petitioner, through           
          her counsel, was invited to supply additional information that              
          would be relevant under section 6015.  No further information was           
          provided.  In a notice of final determination sent October 5,               
          1999, respondent determined that petitioner was entitled to the             
          partial relief for 1987 described above.  Respondent further                
          determined that petitioner had not shown that she met the                   
          requirements of section 6015(b) or (c) for 1992 and that she did            
          not file a joint return for 1995.  Petitioner had not claimed               
          relief under section 6015(f), and no determination was made                 
          specifically referring to that section.                                     
               At the time of trial in May 2001, the original returns filed           
          by petitioner and H. Smith for 1987 and 1992 were no longer                 
          available.                                                                  






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