Fay Dalton, Petitioner, and Robert Dalton, Intervenor - Page 10




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               Because the 1995 tax liability was paid in full, no relief             
          is available to petitioner under section 6015(c).  Petitioner               
          admits to knowing about the pension income, unemployment                    
          compensation, and State income tax refund and is therefore not              
          eligible for relief from joint liability under section 6015(b)              
          with respect to those items of unreported income.                           
               As to the $472 in barter income, respondent argues that                
          petitioner does not qualify for relief under section 6015(b)                
          because petitioner’s knowledge of intervenor’s relationship with            
          Itex gave petitioner reason to know of the income earned by                 
          intervenor from the bartering activity.  We agree.                          
               Although some factors arguably support petitioner’s claim to           
          equitable relief under section 6015(f) as to the total $1,808               
          petitioner paid, the evidence does not establish that respondent            
          abused his discretion in denying such relief.  We note                      
          particularly petitioner’s actual knowledge of three of the four             
          items of unreported income, and we note petitioner’s various tax            
          protester arguments made herein.                                            
               Petitioner is not entitled to relief from any portion of the           
          tax, interest, and penalties she paid with respect to her 1995              
          joint Federal income tax liability.                                         

                                             Decision will be entered for             
                                        respondent.                                   







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