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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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