E. Carolyn Mellen - Page 10




                                                - 10 -                                                  
            for their taxable year 1995 and to the immediate assessment and                             
            collection of a deficiency of $9,719 in Federal income tax, a                               
            penalty of $486, and interest as provided by law.  On November                              
            23, 1998, respondent assessed those amounts as well as interest                             
            accruals thereon.  (We shall refer to those assessed amounts as                             
            well as interest as provided by law accrued after November 23,                              
            1998, as petitioner’s unpaid liability for 1995.)                                           
                  Petitioner did not enter into an installment agreement or                             
            other arrangement to pay petitioner’s unpaid liability for 1995.                            
            Nor did petitioner at any time attempt to borrow money on an                                
            unsecured or secured basis in order to pay petitioner’s unpaid                              
            liability for 1995.                                                                         
                  On March 26, 1999, petitioner filed with respondent Form                              
            8857, Request for Innocent Spouse Relief (And Separation of                                 
            Liability and Equitable Relief), with respect to petitioner’s                               
            unpaid liability for 1995.  (We shall refer to Form 8857 that                               
            petitioner filed with respondent as petitioner’s Form 8857.)                                
            Petitioner attached the following statement to petitioner’s Form                            
            8857:                                                                                       
                  TO WHOM IT MAY CONCERN:                                                               
                        I am submitting this form because I am qualified                                
                  in every way for equitable relief.                                                    
                        I and my spouse have no community property.  What                               
                  property I do have is an inheritance from my parent’s                                 
                  estate.                                                                               
                        My husband runs his own business and is self-                                   





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011