- 5 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011