Marc S. Feldman - Page 6

                                        - 6 -                                         
               On February 26, 1999, the IRS proposed adjustments to                  
          petitioner and Ms. Trevino’s 1996 tax liability for underreported           
          interest and rental income.  Petitioner paid the proposed                   
          adjustments on March 5, 1999.  On March 5, 1999, petitioner also            
          agreed to a proposed adjustment to the 1997 liability, increasing           
          total taxable income.  Respondent adjusted the charitable                   
          contribution amount claimed in petitioner and Ms. Trevino’s                 
          itemized deductions.  Petitioner signed the audit report on                 
          March 5, 1999, and Ms. Trevino signed it on April 2, 1999.  On              
          May 6, 1999, respondent determined that petitioner’s 1996 and               
          1997 income tax liabilities were then currently uncollectible.              
          On September 16, 1999, petitioner signed an audit report agreeing           
          to additional adjustments to the 1996 return.  On October 1,                
          1999, Ms. Trevino signed the report.                                        
               On October 29, 1999, the IRS denied petitioner’s request for           
          relief from joint and several liability.  Attached to the denial            
          letter was a Form 886A, Explanation of Items.  Relief was denied            
          because the tax liability was attributable to petitioner’s                  
          partnership income and there was insufficient evidence to show              
          that petitioner would suffer economic hardship if not relieved              
          from the liability.  On November 23, 1999, petitioner protested             
          the denial of relief and requested review by the Appeals Office.            
          On October 31, 2001, the Appeals Office sent a Notice of                    
          Determination Concerning Your Request for Relief from Joint and             






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011