- 2 - The petition in this case was filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. Pursuant to section 6330(d),1 petitioner seeks review of respondent's determination to proceed with collection of her tax liability of $7,808 for 1994. The issue for decision is whether respondent abused his discretion by denying petitioner's request for relief from joint and several liability under section 6015(f).2 The stipulated facts and exhibits received into evidence are incorporated herein by reference. At the time the petition in this case was filed, petitioner resided in Vienna, Virginia. Background Petitioner and her former spouse, Arnold Pierce, were married on August 3, 1973. Petitioner resided with Mr. Pierce until their permanent separation in November 1994. In 1994, both petitioner and Mr. Pierce worked at the Department of Defense (DOD). At the time their 1994 Federal income tax return was 1 Sec. 6330 was enacted as part of the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L. 105-206, sec. 3401, 112 Stat. 746. Sec. 6330 is effective with respect to collection actions initiated more than 180 days after July 22, 1998; i.e., after Jan. 18, 1999. See RRA 1998 sec. 3401(d), 112 Stat. 750. 2 Sec. 6015 was enacted as part of the RRA 1998, sec. 3201(a), 112 Stat. 734, and is effective for any liability for tax arising after July 22, 1998, and any liability for tax arising on or before July 22, 1998, but remaining unpaid as of July 22, 1998.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011