Marianne Hopkins - Page 28

                                       - 28 -                                         
               In determining an individual’s entitlement to relief under             
          section 6015(f) for an underpayment, the Commissioner considers             
          the requesting spouse’s knowledge, or reason to know, that the              
          liability would be unpaid at the time the return was signed, as a           
          factor weighing against relief.  Rev. Proc. 2000-15, sec.                   
          4.03(2)(b), 2000-1 C.B. 447, 449.                                           
               Petitioner has not shown to our satisfaction that she had no           
          knowledge, or reason to know, that the taxes reported on the                
          joint returns for 1988 and 1989 would not be paid.  The record              
          indicates that she was involved in the preparation of the returns           
          for those years.  Indeed, the 1989 joint tax return contains an             
          attached Form 2688, Application for Additional Extension of Time            
          to File U.S. Individual Income Tax Return, dated August 14, 1990,           
          which states:                                                               
               At present we are not able to meet more demands of the                 
               IRS than we have already on hand.  We are physically                   
               ill and emotionally sick.  All of us are suffering from                
               POST TRAUMATIC STRESS SYNDROMS.                                        
               In spite of our conditions, we are currently dealing                   
               with the IRS on a major scale:  our casualty loss                      
               investigation.  Our home and all of our belongings were                
               destroyed by a huge mudslide.  We barely escaped with                  
               our lives.  We are financially devastated.  We can not                 
               do more.                                                               
               Please honor our request for an extension of this                      
               matter until the casualty loss investigation is                        
               Thank you!  * * * [signed Marianne Hopkins].                           

Page:  Previous  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  Next

Last modified: May 25, 2011