Janice L. Cardiff, f.k.a. Janice Dunn, Petitioner, and Stephen Dunn, Intervenor - Page 4

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          underpayment of 1994 income taxes at issue herein, as well as for           
          an unpaid income tax deficiency for 1992.                                   
               In the Final Notice of Determination dated July 24, 2002,              
          respondent granted partial relief (50 percent) to petitioner from           
          joint and several liability for the tax liability on the 1994               
          joint return.                                                               
               After petitioner filed the petition in this case, the                  
          administrative file was forwarded to the San Diego Appeals Office           
          for consideration.  The Appeals Officer recommended that                    
          petitioner be granted full relief from joint and several                    
          liability for the underpayment as requested, rather than only 50            
          percent relief as previously determined.                                    
               Intervenor filed his Notice of Intervention on December 31,            
          2002.  He disputes that petitioner is entitled to full equitable            
          relief from joint liability instead of the 50 percent relief                
          previously granted by respondent in the final determination                 
          letter upon which petitioner’s case is based.                               
               In this case, we are concerned only with section 6015(f).              
          Section 6015(f) provides in pertinent part:                                 
               SEC. 6015(f).  Equitable Relief.–-Under procedures                     
               prescribed by the Secretary, if--                                      
                    (1) taking into account all the facts and                         
                    circumstances, it is inequitable to hold the individual           
                    liable for any unpaid tax or any deficiency (or any               
                    portion of either);                                               
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