Ruthe G. Ohrman - Page 21

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          her, petitioner instructed Rackner to draft the separation                  
          agreement whereby she would be financially separated from                   
          Mr. Ohrman.  Fourth, pursuant to this separation agreement,                 
          petitioner received approximately $782,000 in assets that had               
          previously been held in Mr. Ohrman’s name along with spousal                
          support amounting to at least $4,000 per month for a minimum                
          period of 78 months, leaving Mr. Ohrman stripped of nearly all of           
          his assets and monthly income.  Finally, petitioner and                     
          Mr. Ohrman have continued their marital relationship since their            
          legal separation was finalized in July 2001 and have continued to           
          use Mr. Ohrman’s income to pay the family’s ongoing living                  
               In Doyle v. Commissioner, T.C. Memo. 2003-96, we denied a              
          taxpayer relief from joint and several liability under section              
          6015(b)(1)(D) because she and her family had engaged in a                   
          systematic plan to put their assets beyond the reach of                     
          respondent’s legitimate collection activities.  Similarly, in               
          Pierce v. Commissioner, T.C. Memo. 2003-188, we denied a taxpayer           
          relief under section 6015(b)(1)(D) when the object of a series of           
          transactions entered into by the taxpayer was to shield assets              
          from creditors, which ultimately included respondent.  In both              
          cases, we concluded that granting relief to taxpayers in such               
          circumstances would wrongfully permit them to shield themselves             
          from Federal tax liabilities by using section 6015.                         

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