120 T.C. No. 9 UNITED STATES TAX COURT CONNIE A. WASHINGTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1828-01. Filed April 21, 2003. P and her then husband, H, filed a joint Federal income tax return for 1989 showing tax owed; they did not pay the tax with the return. R garnished P’s wages and applied P’s overpayments of tax from 1992 and 1994-98 to the unpaid 1989 tax liability. P requested relief under sec. 6015(f), I.R.C. R denied P’s request for relief. P then filed a petition in this Court seeking a review of R’s determination and requesting (pursuant to sec. 6015(g), I.R.C.) a refund of her garnished wages and the overpayments of tax from 1992 and 1994-98. R asserts that even if P is entitled to relief under sec. 6015(f), I.R.C., sec. 6015, I.R.C., does not apply to the portion of the tax liability that was paid on or before July 22, 1998. Held: P is entitled to relief under sec. 6015(g), I.R.C. R’s denial of such relief was an abuse of discretion.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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