Jacquelyn Brown - Page 3




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          B.   Assessment and Payment of the Browns’ 1988 Tax Liability               
               Respondent mailed the Browns a notice of deficiency for                
          1988-90 on March 25, 1994.  In it, respondent determined that the           
          compensation that Brown had reported as income from self-                   
          employment was wages.  Neither petitioner nor Brown filed a                 
          petition in the Tax Court in response to the notice of                      
          deficiency.  On August 10, 1994, respondent assessed taxes based            
          on the March 25, 1994, notice of deficiency.                                
               Respondent applied the Browns’ overpayments of tax for 1994,           
          1995, 1996, and 1997 to their 1988 tax liability as follows:                
                      Year of            Date           Amount                        
                     overpayment        applied         applied                       
          1994          May 1, 1995         $179                                      
          1995          Apr. 29, 1996      1,801                                      
          1994          May 20, 1996       1,196                                      
          1996          Apr. 21, 1997      2,507                                      
          1997          May 18, 1998       3,054                                      
               The Browns’ 1988 tax liability was paid in full on May 18,             
          1998.                                                                       
                                       OPINION                                        
               Petitioner contends that she is entitled to relief from                
          joint and several liability for 1988 under section 6015.  We                
          disagree.  Section 6015 does not apply to any liability for tax             
          arising before July 22, 1998, except to the extent it remained              
          unpaid as of that date.  Internal Revenue Service Restructuring             
          and Reform Act of 1998 (RRA), Pub. L. 105-206, sec. 3201(g)(1),             
          112 Stat. 740; Butler v. Commissioner, 114 T.C. 276, 281-282                




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