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Background
On May 13, 1999, respondent applied, pursuant to section
6402(a), petitioner’s overpayment, relating to 1998, as a credit
against a portion of petitioner’s 1989 tax liability and sent
petitioner written notification thereof. On July 23, 2001,
petitioner requested, pursuant to section 6015(b), (c), and (f),
relief from joint and several liability relating to her 1989
joint Federal income tax return filed with Alvin L. Campbell.
By Final Notice of Determination dated November 6, 2001,
respondent determined that petitioner was not entitled to relief
from joint and several liability relating to 1989 because the
request was, pursuant to section 6015, filed more than 2 years
after respondent’s first collection activity against petitioner.
On February 1, 2002, petitioner, while residing in Tucson,
Arizona, filed a petition pursuant to section 6015(e)(1) seeking
review of respondent’s determination. Petitioner, on March 10,
2003, filed a Motion for Partial Summary Judgment, accompanied by
a Memorandum of Points and Authorities, and Affidavit in support
thereof. On March 31, 2003, respondent filed a Notice of
Objection and Cross-Motion for Summary Judgment, accompanied by
Declarations, and Memorandum of Law in support thereof.
Petitioner, on April 16, 2003, filed an Opposition to
Respondent’s Cross-Motion for Summary Judgment.
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Last modified: May 25, 2011