- 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 concluded. 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