Lisa Marie Pierce - Page 3

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               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.                                                              




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