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On May 1, 2000, respondent issued to petitioner a letter in
response to petitioner’s request for relief from joint and
several liability with respect to petitioner’s taxable year 1993.
That letter stated, inter alia:
Ms. Susan Castle is not entitled to relief from any tax
liability under the provisions of Internal Revenue Code
6015(b), 6015(c) nor 6015(f).
It was determined that Ms. Castle knew or had reason to
know of the deficiency, and she failed to prove that a
hardship would result if she were to pay the liability.
On June 23, 2000, respondent issued to petitioner a final
notice (final notice) of respondent’s determination that peti-
tioner is not entitled to relief from joint and several liability
under either section 6015(b), (c), or (f) with respect to peti-
tioner’s taxable year 1993. With respect to respondent’s deter-
mination under section 6015(f), the final notice stated: “It is
determined that you do not qualify for equitable relief under IRC
Section 6015(f). You have not established all the elements
necessary to grant you relief.”
At the time of the trial in this case, the total assessed
but unpaid liability with respect to the 1993 joint return (not
including certain accruals) was $31,642.34 (the unpaid 1993
liability).
OPINION
We review respondent’s denial of relief under section
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