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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
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