Ruthe G. Ohrman - Page 13

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               In August 2002, Revenue Agent Joan McConnell (McConnell) was           
          assigned to examine petitioner’s qualification for relief from              
          joint and several liability under section 6015.  McConnell                  
          interviewed petitioner on September 11, 2002.  During this                  
          interview, petitioner told McConnell that monthly statements for            
          the Dean Witter account came to the Birdshill residence during              
          1999, but she did not open them because they were not addressed             
          to her.  Additionally, petitioner explained to McConnell that she           
          obtained the legal separation from Mr. Ohrman in order to protect           
          herself financially.  Petitioner also provided to McConnell a               
          written response to respondent’s Innocent Spouse Questionnaire at           
          this interview and signed it under penalties of perjury.                    
               McConnell interviewed Mr. Ohrman on October 31, 2002.  When            
          questioned during this interview about the transfer of assets to            
          petitioner, Mr. Ohrman told McConnell that the legal separation             
          and transfer of assets were his ideas and that he did not feel              
          that petitioner should have to pay for his mistakes.                        
               McConnell referred to Rev. Proc. 2000-15, 2000-1 C.B. 447,             
          to determine whether petitioner should be granted equitable                 
          relief under section 6015(f) for the 1999 tax deficiency.  Based            
          upon her analysis of the facts and circumstances of petitioner’s            
          case, McConnell determined that petitioner did not qualify for              
          equitable relief under section 6015(f).  McConnell concluded that           
          petitioner received a transfer of disqualified assets from                  

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