Rosalinda E. Alt - Page 9




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               Year       Dr. Alt       Petitioner       Total                          
               1997      $13,200         $39,375        $52,575                         
               1998      35,246          105,655        140,901                         
               1999      53,761          83,987         137,748                         
               2000      100,800         74,154         174,954                         
          Currently, petitioner and Dr. Alt financially support no one                  
          other than each other.                                                        
               On April 14, 2000, respondent received Form 8857, Request                
          for Innocent Spouse Relief, from petitioner for taxable years                 
          1982 through 1989.  On August 8, 2000, Revenue Agent Susan Carene             
          met with petitioner to discuss the request.  On September 29,                 
          2000, respondent sent petitioner a letter determining that she                
          was not entitled to any relief under section 6015(b), (c), and                
          (f) for the taxable years 1982 through 1988.  The same day,                   
          respondent sent petitioner a letter determining that no relief                
          under section 6015 was available for 1989 because petitioner did              
          not file a joint return for that year.  On October 30, 2000,                  
          respondent received a Form 12509, Statement of Disagreement, from             
          petitioner disputing the determinations.  On December 8, 2000,                
          respondent sent petitioner a final notice of determination in                 
          which respondent determined that petitioner was not entitled to               
          relief under section 6015(b), (c), and (f) for the taxable years              
          1982 through 1988.                                                            











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