- 3 -
On April 30, 1999, respondent mailed a notice of deficiency
to petitioner and intervenor for their 1993 and 1994 tax years.
As a result of supplemental substantiation from intervenor after
the issuance of the notice of deficiency, respondent concedes
that there is no deficiency in income tax due from either
petitioner or intervenor for 1994. On the basis of the
supplemental information provided by intervenor, respondent
decreased the 1993 deficiency and addition to tax amounts
determined in the notice of deficiency and currently claims that
there is a deficiency of $2,863 and an addition to tax of $546
for 1993. The revised 1993 deficiency stems from respondent’s
disallowance, for lack of substantiation, of a portion of costs
of goods sold and business expenses reported on the Schedule C
for Mike’s Painting. A portion of the revised deficiency is
attributable to an increase in self-employment tax due to the
adjustments to the Schedule C.
On June 14, 1999, petitioner filed her petition with this
Court. At approximately the same time, petitioner submitted to
respondent a Form 8857, Request for Innocent Spouse Relief (And
Separation of Liability and Equitable Relief), requesting relief
under section 6015. Petitioner subsequently amended her petition
to claim relief under section 6015. Petitioner included a copy
of her Form 8857 with her amended petition.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011