- 5 - expenses. Respondent additionally allowed $400 of the $4,032 for labor expenses, but disallowed the remaining expenses because there was no record that Forms 1099, Miscellaneous Income, were issued. Respondent further allowed $1,200 of the $4,441 claimed for small tools expense. Petitioner then stipulated to a deficiency of $4,478 plus interest. A decision was entered by the Court on December 17, 1998. On April 19, 1999, respondent sent to petitioner a notice of intent to levy. On May 3, 1999, petitioner timely filed Form 8857, Request for Innocent Spouse Relief, requesting section 6015 relief from joint and several liability for the year in issue. On March 15, 2001, respondent sent to petitioner a notice of determination denying section 6015 relief. The determination was based on the conclusion that petitioner had knowledge of the business and its activities that precluded relief. In an amendment to the answer filed April 22, 2002, in this case, respondent raised the defense of res judicata. On March 10, 2000, respondent applied an overpayment of $2,323 from petitioner’s 1999 Federal income tax return towards the 1994 liability. Following the March 15, 2001, determination, respondent applied an overpayment of $2,367 from petitioner’s 2000 Federal income tax return towards the remaining 1994 liability. On April 15, 2002, respondent notified petitioner that her 2001 refund of $1,895 was delayed until respondentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011