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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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