Laura L. Brooks - Page 4

                                        - 4 -                                         
               On September 18, 2000, respondent determined petitioner was            
          not entitled to section 6015 relief because she had actual                  
          knowledge of the income that caused the understatement of tax,              
          and it would not be inequitable to hold petitioner liable for the           
          tax.  By notice dated September 25, 2000, respondent informed               
          petitioner of his determination.                                            
               On July 12, 2001, petitioner, while residing in Silver                 
          Springs, Florida, filed her petition with this Court, in which              
          she contends that she is entitled to section 6015 relief.  On               
          September 10, 2001, respondent gave notice of petitioner’s                  
          contention to Mr. Tice.                                                     
                                       OPINION                                        
               Respondent contends that petitioner is not entitled to                 
          section 6015 relief because she knew the nature of Mr. Tice’s               
          work with TDI, the amount he was paid, and that such compensation           
          was not reported on their joint return.  Respondent contends                
          that, but for the omission of income relating to TDI, petitioner            
          and Mr. Tice would not have qualified for a $961 earned income              
          credit.                                                                     
               Generally, taxpayers filing joint Federal income tax returns           
          are jointly and severally liable for all taxes due.  Sec.                   
          6013(d)(3).  In limited situations, however, taxpayers may be               
          relieved of joint liability.  Sec. 6015.  Petitioner is not                 
          entitled to relief pursuant to section 6015(b) or (c), if she had           






Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011