Kathryn Bernal - Page 5




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                    paid or going to be paid at the time you                          
                    signed the return.                                                
                    *  You would be unable to pay basic living                        
                    expenses if not relieved of the liability.                        
                    *  Your spouse has a legal obligation to pay                      
                    the tax debt.                                                     
                    *  You are in compliance with federal tax                         
                    laws.                                                             
               The other notice of determination dated August 13, 2001,               
          relates to the taxable years 1993, 1994, 1995, and 1996.  The               
          explanation of items attached to that notice stated as follows:             
               You have not established that you met the requirements                 
               of I.R.C. section 66(c) for innocent spouse relief.                    
                    You have not met the following factors:                           
                    *  You did not know or have reason to know                        
                    of your husband’s community income.                               
                    *  You have economic hardship.                                    
                    *  Your ex-husband is legally obligated to                        
                    pay tax debt.                                                     
                    *  You are in full compliance with federal                        
                    tax laws.                                                         
          The notice of determination also stated in part as follows:                 
               we cannot grant your request for innocent spouse relief                
               under Section 66(c) of the Internal Revenue Code from                  
               the unpaid balance and/or understatement of the tax * *                
               *                                                                      
                  *       *       *       *       *       *       *                   
                    You can contest our determination by filing a                     
               petition with the United States Tax Court.  You have 90                
               days from the date of this letter to file your                         
               petition. * * *                                                        











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