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check boxes, Letter 3279(DO)(Rev. 1-2001), as a final notice of
the Commissioner’s determination that a taxpayer is not entitled
to relief from joint and several liability on a joint return
under either section 6015(b), (c), or (f). The form letter also
served to advise the taxpayer that “You can contest our
determination by filing a petition with the United States Tax
Court.”
On June 4, 2002, respondent sent petitioner Letter
3279(DO)(Rev. 1-2001). Respondent modified the letter by
manually typing in the following check box and sentence:
: You are not entitled to equitable relief of
liability for the unpaid tax under Section 66(c) of
the Internal Revenue Code.
F. Petitioner’s Petition
Petitioner appealed respondent’s determination by filing a
petition with this Court, which was docketed as a petition for
determination of relief from joint and several liability on a
joint return.
In her petition, petitioner does not identify or invoke any
section of the Internal Revenue Code under which she seeks
relief. However, the crux of petitioner’s position is clearly
revealed in the following passages from the petition:
According to state community property laws, if I had
not have to claim half his [Mr. Sonnabend’s] income, I
would not have owed anything.
If you were only to look at my income–-and my
withholding–-and my payments--I should receive a
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Last modified: May 25, 2011