Connie A. Washington - Page 40

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          1999; we believe such refund claim was filed earlier than that              
          date.                                                                       
               In a letter to Revenue Officer Whalen, dated July 15, 1998,            
          petitioner pleaded financial hardship and asked whether anything            
          could be done to place her account on an “uncollectible status”.            
          Moreover, she requested that the penalties and interest assessed            
          against her be abated, reiterating that the taxes were attributable         
          to her former husband’s business.  Another letter to Revenue                
          Officer Whalen, dated March 13, 1999, referenced earlier meetings,          
          indicating that petitioner’s discussions with Revenue Officer               
          Whalen were ongoing.  In that letter, petitioner stated that                
          garnishment of her wages would cause her a serious financial                
          hardship and asked to be relieved of the 1989 tax liability.  She           
          specifically stated:  “I have filed my taxes faithfully every year          
          only to have my taxes taken for something I was not responsible             
          for.”  On June 29, 1999, petitioner filed Form 8857 in which she            
          sought relief from joint liability for the years 1995-98.                   
          Petitioner requested tax refunds with interest for each of the              
          years 1995-98 in a letter she attached to the Form 8857.                    
               We are satisfied that petitioner’s letters of July 15, 1998,           
          and March 13, 1999, constitute a request for relief within the              
          purview of section 6015.  The ongoing nature of petitioner’s                
          request, and the proximity of the July 15, 1998, letter to the July         
          22, 1998, enactment date of section 6015, lead us to conclude that          






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