Lisa Marie Pierce - Page 8

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               Respondent's position is that petitioner is not entitled to            
          relief from joint and several liability because she failed to               
          establish that she had a reasonable belief that the tax was paid            
          or going to be paid at the time she signed the return.                      
          Respondent also argues that petitioner would not suffer from                
          economic hardship as a result of being denied relief.  Lastly,              
          there was no evidence of abuse to sustain any relief from joint             
          and several liability.                                                      
               Petitioner argues that she is entitled to relief from joint            
          and several liability because Mr. Pierce did not take care of the           
          finances properly, forged her signature, and subjected her to               
          emotional abuse.  She also argues that she trusted her husband              
          and had no reason to know or assume that he might not pay their             
          tax liability.                                                              
                                     Discussion                                       
               Pursuant to section 6330, petitioner sought relief from                
          respondent’s notice of determination sustaining the proposed levy           
          action.  Section 6330 allows a taxpayer to raise appropriate                
          spousal defenses under section 6015.  Sec. 6330(c)(I)(A)(i); sec.           
          301.6330-1(e)(2), Proced. & Admin. Regs.  The Court's                       
          jurisdiction in this case, therefore, is based on section                   
          6015(e)(1).  Raymond v.  Commissioner, 119 T.C. 191 (2002); sec.            
          301.6330-1(f)(2), Q&A-F2, Proced. & Admin. Regs.                            








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